Rush Creek 345 Kv Transmission Line Project Arapahoe County 1041 Permit Application 1041 Permit-REV03

November 10, 2016

PUBLIC SERVICE COMPANY OF COLORADO Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Permit Application 1041 Permit-REV03

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Arapahoe County 1041 Permit Application

PREPARED FOR: PUBLIC SERVICE COMPANY OF COLORADO PREPARED BY: POWER ENGINEERS INC. LAKEWOOD, CO

Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

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Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

EXECUTIVE SUMMARY Public Service Company of Colorado (PSCo or “Applicant”) has prepared this Areas and Activities of State Interest (Colorado House Bill 1041; 1041 Regulations) permit application per the requirements outlined in Chapter 5 of the Regulations Governing Areas and Activities of State Interest in Arapahoe County. This application is organized based on the 2012 Eastern Colorado Connect LLC application per the request of the Arapahoe County Public Works and Development, Planning Division. PSCo is providing Project information, exhibits, and materials, which are hereby incorporated into and made part of the Application below in order to comply with Arapahoe County 1041 Permit approval criteria.

PROJECT SUMMARY The Rush Creek 345 kV Transmission Line Project is an approximately 80-93 mile long (depending on the preferred alternative) 345 kV transmission line, planned to cross approximately 13.5 miles of eastern Arapahoe County, approximately 41 miles of Elbert County, and 26 miles of Lincoln County as depicted on the map in Figure 2-1 (Arapahoe County – Rush Creek 345 kV Transmission Line Project Map). The Project will interconnect approximately 600 MW of proposed wind-generated electricity from the proposed Rush Creek I and II Wind Farms into the existing Missile Site Substation in Arapahoe County. Rush Creek I is located in Elbert County and Rush Creek II is located in Cheyenne, Kit Carson, and Lincoln Counties. Although information about the Project as a whole is submitted herein, the subject of this Application is the Rush Creek 345 kV Transmission Line Project in Arapahoe County.

For this Project, PSCo analyzed eight end-to-end route alternatives (Alternatives A – H) and selected a Preferred Alternative for the entire Rush Creek 345 kV Transmission Line Project. When considering landowner interest, both within Arapahoe County and along the entire transmission line route, the selected Preferred Alternative was designed to balance minimizing the number of residences passed along the route within Arapahoe County, minimizing the distance passed through sensitive environmental areas, and minimizing impacts to various resources while maximizing engineering design optimization and the purpose and need of the Project. Alternative A was selected as the Preferred Alternative. Alternative A would be the longest alternative through Arapahoe County; however, it would minimize impacts to several key resources and would parallel the existing NextEra 345 kV Transmission Line for its entire length in Arapahoe County. The Preferred Alternative would pass by the fewest number of residences within 1,000 feet and crosses the fewest number of wetlands and floodplains. The Preferred Alternative would rank second for the number of stream crossings and the number of miles through Arapahoe County Sensitive Development Areas; three miles of the preliminary selected route in Arapahoe County were relocated to the west to avoid riparian habitat areas associated with the Muddy Creek drainage. The Preferred Alternative would pass through the most miles of potential prime farmland; however, soils comprising these lands are considered only potential prime farmland and are classified as prime if they are irrigated. The Preferred Alternative would rank second for miles passing through agricultural cropland lands and shortgrass prairie.

Upon completion of permitting activities and approval by Cheyenne, Elbert, Lincoln, and Kit Carson Counties for the Rush Creek Wind Project, PSCo will purchase the Project. PSCo will own, operate, and maintain the wind farm and transmission line facilities. Invenergy, LLC is responsible for planning and permitting the wind farm that the proposed transmission line will interconnect into PSCo’s grid at the Missile Site Substation. PSCo’s planned involvement in the Rush Creek Wind Project was publicly announced on April 12, 2016 by the Company and in local and regional news outlets. More information

I Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

about the planned transaction can be found at http://www.transmission.xcelenergy.com/Projects/Colorado/Rush-Creek-Connect.

The Project may include all or any of the following (collectively, “Transmission Line Facility”): (i) overhead electrical transmission and communications lines, transmission line structures, electric transformers, electric substation improvements at the Missile Site Substation, and other necessary interconnection facilities; (ii) construction and maintenance access roads; and (iii) temporary construction material and assembly yard(s).

The Potential Arapahoe County Transmission Line Right of Way (ROW) Lease Names and Parcels for the Project Area are listed in Appendix A. Upon execution of the land leases with the landowners PSCo would be granted the sole and exclusive right to use the subject property for constructing, operating, and maintaining the proposed 345 kV transmission line. This includes all transmission line project development activities, of which local permitting is included. Upon execution, the Land Leases are recorded with Arapahoe County for this portion of the Project Area. Appendix B lists the Arapahoe County Parcel Township-Range-Section information within the Arapahoe County Project Area.

The following Application and supporting documents address Arapahoe County 1041 Permit Application criteria specific to a Transmission Line Facility. Should any questions arise concerning the submittal or other considerations related to this Application, please contact the following party:

Public Service Company of Colorado Erin A. Degutis, RLA, AICP, LEED AP 1800 Larimer Street , 4th Floor Senior Agent, Siting and Land Rights Denver, Colorado 80202 Public Service Company of Colorado d/b/a Xcel Energy Services, Inc. Telephone: 303.571.7735 Email: [email protected]

II Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

TABLE OF CONTENTS

Arapahoe County 1041 Permit Application ...... 1 1041 APPROVAL CRITERIA ...... 3 A. General Approval Criteria ...... 3 C. Additional Criteria Applicable to Major Facilities of a Public Utility ...... 14 1. Applicant Information ...... 17 1.1 Applicant Address and Contact...... 17 1.2 Background on Xcel Energy, Inc. and Public Service Company of Colorado...... 17 1.3 Legal Description and Disclosure of Ownership ...... 18 1.4 Project Finances ...... 18 2. Project Description ...... 21 2.1 Project Purpose and Need ...... 21 2.2 Project Overview...... 21 2.3 Rush Creek Wind and Transmission Project Overview ...... 22 2.4 Arapahoe County Project Site Description ...... 23 2.5 Transmission Line Siting Overview and Alternative Analysis Summary ...... 23 2.5.1 Transmission Line Siting Overview ...... 23 2.5.2 Transmission Line Alternatives and Analysis Summary...... 30 2.5.3 Selection of the Preferred Alternative ...... 37 2.6 Project Features ...... 38 2.6.1 Transmission Line ...... 38 2.6.2 Substations ...... 41 2.6.3 Right-of-Way Acquisition ...... 41 2.6.4 Access Roads ...... 42 2.6.5 Laydown / Material Staging Areas ...... 42 2.6.6 Protection of Private Property and Resources ...... 42 2.7 Construction Activities ...... 45 2.7.1 Transmission Line Construction ...... 45 2.8 Operation and Maintenance ...... 48 2.8.1 Permitted Uses ...... 48 2.8.2 Maintenance ...... 48 2.9 Traffic Safety ...... 48 2.10 Agency Coordination ...... 49 3. Regulatory Framework ...... 51 3.1 Conformance with Arapahoe County Land Use Plans ...... 51 4. Environmental Resources: Existing Conditions ...... 53 4.1 Land Use and Recreation ...... 53 4.1.1 Existing Conditions ...... 53 4.2 Transportation ...... 55 4.2.1 Existing Conditions ...... 56 4.3 Visual Resources and Aesthetics ...... 57

III Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

4.3.1 Regional Context ...... 57 4.4 Soils, Geology and Natural Hazards ...... 58 4.4.1 Regulations ...... 58 4.4.2 Existing Conditions ...... 59 4.5 Water Resources and Wetlands ...... 61 4.5.1 Regulations ...... 61 4.5.2 Existing Conditions ...... 62 4.6 Biological Resources ...... 64 4.6.1 Introduction ...... 64 4.6.2 Existing Conditions ...... 65 4.7 Paleontological and Cultural Resources ...... 75 4.7.1 Existing Conditions ...... 75 4.8 Socioeconomics...... 75 4.8.1 Existing Conditions ...... 76 5. Environmental Impacts, Mitigation, and Best Management Practices ...... 79 5.1 Land Use and Recreation ...... 79 5.1.1 Impacts and Mitigation ...... 79 5.2 Transportation ...... 82 5.2.1 General Impacts ...... 82 5.2.2 County Specific Impacts ...... 83 5.3 Visual Resources and Aesthetics ...... 84 5.3.1 Alternatives A (Preferred Alternative), B, E, and H ...... 84 5.3.2 Alternatives C, F, and G ...... 85 5.3.3 Alternative D ...... 85 5.4 Soils, Geology and Natural Hazards ...... 86 5.4.1 Impacts Common to All Alternatives ...... 86 5.4.2 End-to-End Route Summary ...... 88 5.5 Water Resources ...... 88 5.5.1 Impacts to Surface Water ...... 88 5.5.2 Impacts to Floodplains ...... 89 5.5.3 Impacts to Ground Water ...... 89 5.5.4 Impacts to Wetlands ...... 89 5.5.5 Impacts Common to Alternatives with Forested Wetlands and Riparian Areas ...... 90 5.5.6 Impacts Common to Alternatives with Geology and Natural Hazards Areas ...... 90 5.5.7 Impacts in Arapahoe County...... 90 5.6 Biological Resources ...... 92 5.6.1 Alternatives A (Preferred Alternative), B, E, and H ...... 92 5.6.2 Alternatives C, F, and G ...... 96 5.6.3 Alternative D ...... 96 5.7 Paleontological and Cultural Resources ...... 97 5.7.1 Arapahoe County ...... 97 5.7.2 End-to-End Route Summary ...... 101 5.8 Air Quality and Controls ...... 102 5.8.1 Existing Emission Sources...... 102 5.8.2 Attainment Status ...... 103 5.8.3 Applicable State Requirements ...... 103

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5.8.4 Construction Emissions ...... 103 5.8.5 Operational Emissions ...... 104 5.8.6 Mitigation Measures ...... 104 5.9 Noise, Vibration, Odors, and Nuisances ...... 104 5.10 Socioeconomics...... 105 5.10.1 General Impacts ...... 105 5.10.2 County-Specific Impacts ...... 107 5.11 Hazards and Emergency Procedures ...... 109 5.11.1 Fire ...... 109 5.11.2 Accidental Spills ...... 109 5.12 Cost-Benefit Analysis ...... 110 6. Engineering Studies ...... 111 6.1 Floodplain Delineation Study ...... 111 6.2 Grading, Erosion, and Sediment Control ...... 111 7. References ...... 113

LIST OF EXHIBITS EXHIBIT A SITE PLAN EXHIBIT A-1 SITE PLAN EXHIBIT B WATER RESOURCES – ARAPAHOE COUNTY MAP EXHIBIT C LAND USE, TRANSPORTATION, AND RECREATION- ARAPAHOE COUNTY MAP EXHIBIT D ZONING, SPECIAL DISTRICTS, AND PARCELS – ARAPAHOE COUNTY MAP EXHIBIT E SCENIC AREAS AND VISUAL QUALITY – ARAPAHOE COUNTY MAP EXHIBIT F PHOTOSIMULATIONS OF PROPOSED TRANSMISSION LINE EXHIBIT G SOIL QUALITIES – ARAPAHOE COUNTY EXHIBIT H TERRESTRIAL AND AQUATIC ANIMAL AND PLANT HABITAT – ARAPAHOE COUNTY EXHIBIT I ARAPAHOE COUNTY - UP RAILROAD AND SEEN/UNSEEN ANALYSIS

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LIST OF APPENDICES APPENDIX A ARAPAHOE COUNTY ROW LEASE NAME AND PARCEL APPENDIX B ARAPAHOE COUNTY PARCEL TOWNSHIP-RANGE-SECTION APPENDIX C DRAFT ARAPAHOE COUNTY ROAD USE AGREEMENT APPENDIX D AGENCY CORRESPONDENCE APPENDIX E CHARACTERISTIC PHOTOS OF ARAPAHOE COUNTY’S LANDSCAPE APPENDIX F VISUAL SIMULATION APPENDIX G PSCO FINANCIAL SUMMARY APPENDIX H UNION PACIFIC RAILROAD SEEN/UNSEEN ANALYSIS AND SITE PHOTOS APPENDIX I ARAPAHOE COUNTY REDLINE REVIEW DOCUMENTS

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ACRONYMS AND ABBREVIATIONS

% percent Access Plan Access and Traffic Control Plan ACLDC Arapahoe County Land Development Code ACSS Aluminum conductor steel supported APCD Air Pollution Control Division APEN Air Pollutant Emission Notice Applicant Public Service Company of Colorado BMP Best Management Practice CDP Census-Designated Place CDPHE Colorado Department of Public Health and Environment CFR Code of Federal Regulations CNHP Colorado Natural Heritage Program CO Carbon monoxide CPW Colorado Parks and Wildlife C.R.S. Colorado Revised Statutes CWA Clean Water Act Denver MSA Denver-Aurora-Lakewood Metropolitan Statistical Area EMF Electromagnetic field FAA Federal Aviation Administration FEMA Federal Emergency Management Agency GESC Grading, Erosion, and Sediment Control Plan GIS Geographic Information System I Interstate IPaC Information, Planning and Conservation kV Kilovolt LOS Level of Service MBTA Migratory Bird Treaty Act mi2 Square mile MLRA Major Land Resource Area MW Megawatt NDIS National Diversity Inventory Database NESC National Electric Safety Code NOx Nitrogen oxides NPDES National Pollution Discharge Elimination System NRCS Natural Resources Conservation Service NRHP National Register of Historic Places NWI National Wetlands Inventory O&M Operation and Maintenance OPGW Fiber optic ground wire PEM Palustrine emergent PFO Palustrine forested PM Particulate matter PM10 Particulate matter less than 10 microns

VII Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

PM2.5 Particulate matter less than 2.5 microns Project 13.5 miles of 345 kV transmission line in Arapahoe County PSCo Public Service Company of Colorado PSS Palustrine scrub-shrub PUB Palustrine unconsolidated bottom PUC Public Utility Commission PUS Palustrine unconsolidated shore R4 Intermittent riverine wetlands RMBO Rocky Mountain Bird Observatory ROW Right-of-Way RPS Renewable portfolio standard SO2 Sulfur dioxide SSURGO Soil Survey Geographic SWPPP Stormwater Pollution Prevention Plan USACE U.S. Army Corps of Engineers U.S.C. United States Code USCB U.S. Census Bureau USDA U.S. Department of Agriculture USEPA U.S. Environmental Protection Agency USFWS U.S. Fish Wildlife Service USR Use by Special Review VOC Volatile organic compound WQC Water Quality Certification Xcel Xcel Energy, Inc.

VIII Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Arapahoe County 1041 Permit Application Rush Creek 345 kV Transmission Line Project

Submitted by Public Service Company of Colorado 1800 Larimer Street, 4th Floor Denver, Colorado 80202

LETTER OF INTENT

Through this application, Public Service Company of Colorado (PSCo) respectfully requests approval of a 1041 Permit Application to construction, operate, and maintain approximately 13.5 miles of 345 kilovolt (kV) transmission line in eastern Arapahoe County (the “Project”). As is customary with all land use applications to locate and construct major utility facilities in Colorado, PSCo is applying pursuant to CRS 29-20-108, which relates to local government processing of such applications.

As discussed in our pre-application and consultation meeting with County staff, the proposed transmission line in Arapahoe County is one component of the proposed Rush Creek wind farm, which consists of 600 MW of new wind generation and 90 new miles of transmission in eastern Colorado. In May 2016 PSCo filed an application for a Certificate of Public Convenience and Necessity (CPCN) with the Colorado Public Utilities Commission (CPUC) for the Rush Creek project. Details about the overall project can be found on the CPUC website under Docket #16A-0117E.

The transmission line proposed in Arapahoe County will deliver wind-generated electricity from Rush Creek to PSCo’s grid by way of the existing Missile Site Substation. During the construction period, temporary staging areas of approximately 20-acres in size will be required to house construction materials and equipment. While the locations of these staging areas are yet to be identified, at least one such area will likely be located in Arapahoe County.

The Project Area within Arapahoe County covered by the 1041 Permit Application is approximately 300 acres, based on an easement width of 150-feet. PSCo is currently negotiating with landowners to acquire easements for construction, operation, and maintenance of the Project. Based on progress to date, we anticipate executing easements or easement option agreements by early fall of this year.

PAGE 1 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

PSCo appreciates the County’s consideration of this application and we look forward to working together on the permitting process. Please let me know if I can provide additional information or assistance. I can be contacted directly via telephone at 303.571.7735 or email at [email protected] .

Kindest regards,

Erin A. Degutis, RLA, AICP, LEED AP Senior Agent, Siting and Land Rights 1800 Larimer Street, 4th Floor Denver, Colorado 80202

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1041 APPROVAL CRITERIA A. General Approval Criteria 1. Documentation that prior to site disturbance associated with the Proposed Project, the applicant can and will obtain all necessary property rights, permits, and approvals.

Prior to site disturbance, Public Service Company of Colorado (PSCo) will obtain and comply with the required approvals pertaining to county, state, and federal regulatory authorities for the construction, operation, and maintenance of the Project in Arapahoe County. PSCo will obtain Arapahoe County land-use, building, grading, erosion, and sediment control, and use of utility right-of-way (ROW) permits in connection with the construction, operation, and maintenance of the transmission line. Material permits applicable to the transmission line in Arapahoe County will include state, stormwater discharge, air (fugitive dust), utility, and oversize load permits. PSCo owns and operates the Missile Site Substation and as a part of this Project, will add equipment to accommodate the new 345 kV transmission line. At the time of this application submission, PSCo is actively coordinating with and actively engaging the eight landowners that parallel the existing NextEra 345 kV transmission line for a ROW easement to accommodate the proposed Rush Creek 345 kV Transmission Line. PSCO anticipates having land use control through easement agreements at the time of public meetings this fall.

2. The Proposed Project considers the relevant provisions of the regional water quality plans.

There will be no significant impact to water resources from transmission line construction, operation, and maintenance. The proposed Project will not affect water quality; there is no water use proposed for the Project except minimal amounts potentially used during construction for fugitive dust control and concrete. No regional water quality plans are affected by the proposed transmission line in Arapahoe County. The Project will be consistent with the Clean Water Act (CWA) and the Colorado Department of Public Health and Environment (CDPHE) Water Quality Control Division authorizations and plans that are applicable (e.g. Stormwater Management Plan; generally referred to as a Stormwater Pollution Prevention Plan [SWPPP]). Please see General Criteria #12(c) and (d) below for more information.

3. The applicant has the necessary expertise and financial capability to develop and operate the Proposed Project consistent with all requirements and conditions.

PSCo is the number one wind-generated electricity provider in the nation for the last twelve consecutive years as determined by the American Wind Energy Association. Clean energy from renewable resources accounts for more than 20 percent of PSCo’s total energy supply. PSCo remains committed to expanding the use of renewable energy in the most economical way for customers. PSCo’s proposed wind project will reduce 1 million tons of carbon each year equal to approximately 3% of total carbon emissions.

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Xcel Energy, the parent company of PSCo, ranks in the top five for natural gas and electric utilities, with high marks for social responsibility, people management, innovation, assets and financial soundness. Xcel Energy is one of Forbes magazine’s 100 Most Trustworthy Companies in America for our consistent demonstration of transparent accounting practices and solid corporate governance. As a public-regulated utility, PSCo is accountable to ratepayers and stockholders in terms of planning and executing energy generation and transmission projects that are fiscally responsible and technically feasible. The Rush Creek Wind Project is a part of Company’s “Our Energy Future,” a forward- thinking plan that addresses future generation and transmission needs in Colorado, including additional renewable energy resources. The Company intends to take advantage of the Renewable Energy Production Tax Credit (PTC), which is an incentive to bring new renewable energy online by meeting specific timeline goals and results in saving ratepayers millions of dollars over the life of the Project.

4. The Proposed Project is technically and financially feasible.

The Project is technically feasible given PSCo’s level of expertise and experience in constructing wind-generated electricity projects. The Rush Creek Wind and Transmission Project will be the largest wind generation facility in Colorado and spans five counties (Arapahoe, Cheyenne, Elbert, Kit Carson, and Lincoln) for the wind and transmission components of the proposed Project collectively. The transmission line would cross only Arapahoe, Elbert, and Lincoln Counties. In Arapahoe County, the Rush Creek Connect 345 kV Project would consist of approximately 13.5 miles of 345 kV transmission line and upgrades to the existing Missile Site Substation. The construction period for the transmission line in Arapahoe County would be approximately 15-20 weeks with activity levels varying from day-to-day during this timeframe. The total cost estimate to construct the entire 80-93 mile long (depending on the alternative route selected) transmission line is approximately $121 million. These costs are financially feasible for PSCo to support, as these costs will initially be paid out of PSCo’s operating capital. Appendix G contains the 2015 financial summary for PSCo.

5. The Proposed Project is not subject to significant risk from natural hazards.

Much of the proposed Project area is considered low risk for geologic hazards. The topography has fairly level relief (0-10 percent slope), with gently rolling terrain and flood plains interspersed by drainages with steeper side slopes. The occurrence of major landslides within the Project Area has not been recorded, although the potential for sheet and rill erosion and gully formation may be moderate to severe in some areas. For seismic purposes, Colorado is considered a region of minor earthquake activity, although there are many uncertainties because of the very short time period for which historic data is available. This portion of Colorado and Arapahoe County can be considered aseismic.

The proposed Project crosses 100-year Arapahoe County defined floodplains. No FEMA defined floodplains are crossed by Alternative A. A floodplain analysis was completed for this application under a separate submittal. PSCo will not place any transmission line structures with FEMA or Arapahoe County defined floodplains.

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6. The Proposed Project is in general conformity with the applicable comprehensive plans.

The Project is in general conformity with the applicable Arapahoe County Comprehensive Plan (Plan) because the Preferred Alternative minimizes impacts to residents, natural resources, and cultural resources and it parallels an existing transmission line corridor for 100% of its length through the County. This Plan is the only applicable comprehensive plan under this criterion. • The Plan’s Policy 4.2(a) recognizes that facilities such as the transmission line will be allowed in the Rural Area on a case-by-case basis, except in sensitive development and riparian corridor areas. The transmission line will be located on privately- and state-owned lands. The transmission line will not be constructed in riparian or Sensitive Development Areas identified under the Plan. • The transmission line will adhere to Policy PFS 4.2 – Achieve Land Use Compatibility, when Siting Regional and Local Utilities requires utilities to be built in a manner that is safe and compatible with surrounding land uses. Zoning districts within the Project Area include Agricultural Estate (A-E) and Agricultural-1 (A-1). The zoning districts are intended to correspond to and implement the “Rural Area Uses” and “Open Space” land use categories designated in the Land Use Plan element of the Comprehensive Plan. The regulations for A-E and A-1 are district-specific which are applied on a district-wide basis and generally relate back to the stated purposes of the zone district. Please see Section 3.1 for more information.

7. The Proposed Project will not have a significant adverse effect on the capability of local government to provide services or exceed the capacity of service delivery systems.

The Project will not require a level of local services or facilities beyond that which is currently available. The Project will likely generate additional traffic on local roads during the construction period, and impacts would be short in duration. Existing PSCo staff will maintain the new transmission line and additional equipment in the Missile Site Substation. PSCo staff are primarily located in the Denver Metro area and would commute to the Missile Site Substation and the transmission line on a periodic or as-needed basis. During the operation of the Project, it is not anticipated that the project would create additional demand on roads, potable water, wastewater, parks, housing, cemeteries, library resources, solid waste, or schools. Traffic impacts during the operation of the project would be de minimis. Temporary housing for workers could be accommodated in the hotels/motels clustered in eastern Aurora area or Limon.

8. The Proposed Project will not create an undue financial burden on existing or future residents of the County.

The Project will not cause adverse effects to the socioeconomic footprint of Eastern Arapahoe County, as the area is rural in nature and low in population. Additional tax revenues will be generated by the Project through the local purchase of materials, fuel,

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food, and housing during the construction period, and taxing of the infrastructure at the Missile Site Substation. Landowners with a transmission line easement would receive payments for the length of their property that is crossed by the transmission line or location of a materials/laydown yard. PSCo would be responsible for maintenance, repair, upgrades or decommissioning of the transmission and substation assets associated with the Project.

9. The Proposed Project will not significantly degrade any substantial sector of the local economy.

The Project will not cause significant impacts or negative effects to the socioeconomic footprint of the eastern area of Arapahoe County. Potential benefits of the Project include economic gain from purchasing construction materials, associated goods and services, improved county road maintenance and improvements, and landowner payments from PSCo which will provide additional income for County residents. These factors should all create positive gains to the local economy.

10. The Proposed Project will not unduly degrade the quality or quantity of recreational opportunities and experience.

There are limited recreational opportunities in the vicinity of the Preferred Alternative in the eastern area of Arapahoe County. No direct or indirect land use impacts on State, County, or local parks, trails, or fishing stream segments are anticipated to occur because there are no parks and recreational areas within 1,000-feet of the Preferred Alternative. As a result, the construction, operation, and maintenance of the transmission line will not significantly affect recreational opportunities in the eastern area of Arapahoe County. There are no conservation easements along the Preferred Alternative that allow for public recreation potential.

11. The planning, design and operation of the Proposed Project will reflect principals of resource conservation, energy efficiency and recycling or reuse.

The Project is a critical element of the Rush Creek Wind Project which will help the PSCo enhance its renewable energy portfolio standard (RPS), thus fulfilling state requirements for increased alternative energy usage. PSCo is a recognized leader in reducing emissions, integrating renewable power and ensuring the responsible transition to a cleaner energy future. This project allows us to continue delivering on this commitment to customers. The Project will reduce 1 million tons of carbon each year equal to approximately 3 percent of total carbon emissions. Upon completion, the transmission line and the Rush Creek Wind Project will be the largest wind-generated electricity facility in Colorado and the eighth largest in the United States at time of commissioning. PSCo will collect the leftover conductor and static line and transport to an off-site recycling contractor. All other material and trash will be collected and transported off-site to an appropriate recycling or solid waste disposal facility.

12. The Proposed Project will not significantly degrade the environment.

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As further described below, the proposed Project will not have significant effects on the environment and will not significantly degrade the environment with the exception of visual resources which will be moderately impacted in the vicinity of the Project corridor as a result of the transmission line’s visibility against the landscape. Please refer to Section 4: Environmental Resources: Existing Conditions and Section 5: Environmental Impacts, Mitigation, and Best Management Practices for an analysis of the environmental impacts to visual and aesthetics resources.

a. Air quality. The Project will not significantly affect air quality in Arapahoe County because it does not generate any new stationary sources that would result in the long-term emission of criteria pollutants during the construction or operation of the Project. Air emission associated with the Project will be short-term, localized, and consist predominantly of mobile construction equipment and low-level fugitive dust. PSCo will primarily use water as a fugitive dust control measure on unpaved public roads during the construction period.

b. Visual quality. The eastern area of Arapahoe County is rural in nature and characterized by flat to rolling topography interspersed with rural residences and agricultural settlements. Electric transmission and distribution lines occur throughout the area. The entire alignment of the Preferred Alternative would parallel an existing transmission line corridor with the existing and proposed ROWs abutted, but not overlapping the adjacent ROW. The Project crosses and parallels the existing NextEra 345 kV transmission line corridors along the Preferred Alternative. The Project would contribute an additional transmission line to the visual landscape, and the Preferred Alternative would cross five public roadways on its alignment through the eastern area of Arapahoe County: County Route 47/Wall Road, East County Route 34/Jolly Road, County Road 229, County Road 18/South Deter-County Route 229/Winters Road, and Hampden Avenue. The Project will mitigate the visual impacts by using transmission structures that are of similar color (dark brown) and design (H-frame) already found in the visual landscape and match the span length between structures. The Project would use non-specular conductors to further reduce visual impacts in Arapahoe County. The Project would use swan diverters on the static line (top two wires of the transmission structure) matching the color, spacing, and location of the NextEra 345 kV transmission line.

c. Surface water quality. The Project will not significantly affect water quality; there is no significant water use proposed for this Project except minimal amounts potentially used during construction for fugitive dust suppression and concrete. However this amount will be transported on-site with a water truck. The potential impacts will be negligible due to the implementation of BMPs and the ability to span water features and drainages, thus avoiding impacts during the construction period.

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Best management practices (BMPs) will be used during the construction period to reduce potential impacts from erosion, sedimentation, and turbidity in surface waters. A Grading, Erosion, and Sediment Control Plan (GESC) will be developed and implemented to meet Arapahoe County requirements. In addition, SWPPP will be developed and implemented for the Project to meet the construction stormwater discharge permit requirements of the CDPHE.

d. Groundwater quality. The depth of water wells in Arapahoe County range from approximately 25 feet to 600 feet (Colorado Division of Water Resources 2016). Aquifers used by the water wells include Laramie Fox Hills, Upper Dawson Quaternary Alluvium, and unnamed aquifers. It is unlikely the Project would affect groundwater to any extent because of BMPs that will be implemented during Project construction. In addition, no water wells would be drilled for the proposed Project. Excavations for transmission line structures may contact very shallow groundwater; however, the groundwater contact would be unlikely to adversely impact this resource because of BMPs that will be implemented during construction. Techniques to avoid and minimize groundwater impacts would include properly maintaining equipment, storing fuels and petroleum away from excavated areas and cleaning up any spills. After application of mitigation measures and BMPs, impacts to groundwater will be negligible and temporary in duration.

e. Wetlands, flood plains, streambed meander limits, recharge areas, and riparian areas. Transmission line structures would not be placed in wetlands, floodplains, streambeds, recharge areas, and riparian areas and there would be no equipment operation within these features in Arapahoe County. Regulated floodplains would be avoided to the extent practicable. The transmission line will likely span all of these areas with overhead conductors; therefore, little to no anticipated adverse impacts would occur to surface water resources. Potential indirect impacts to water resources could occur from construction related erosion and sediment movement, which are covered by BMPs and the applicable SWPPP and GESC. The potential impacts will be negligible to minor due to the ability to span water features and avoid impacts during construction.

f. Terrestrial and aquatic animal life. The majority of impacts to wildlife will be localized and short-term, related to the removal of vegetation, compaction of soils, noise disturbance, and human presence associated with construction activities. Direct impacts to wildlife during construction will be minimal, as most wildlife will be able to disperse into adjacent habitat. PSCo will follow Colorado Parks and Wildlife (CPW) recommendations to minimize impacts on wildlife such as conducting pre-construction nest surveys, establishing appropriate nest buffer zones, and conducting pre-construction presence/absence surveys for state listed species. Impacts to surface vegetation can reduce foraging habitat from direct disturbance as well as indirectly from increases in noxious weeds; however, the potential for the introduction and/or

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spread of noxious weeds will be minimized by implementing BMPs such as ensuring construction equipment is cleaned, using weed-free seed mixes and controlling noxious weeds within the ROW . The potential for the introduction and/or spread of invasive non-native species (including noxious weeds) will be minimized by the implementation of BMPs during the construction period and reclamation efforts.

Impacts to wildlife during maintenance activities will be minimal due to the selection and type of durable materials used for construction of the transmission line and ability to observe the transmission line from the air. The Missile Site Substation would receive periodic maintenance, but this activity would be confined to the interior of the substation where the area has been previous disturbance and no surface habitat presently exists.

Table 4-2 lists all of the federal and state listed species, including the potential suitable habitat. Section 5.6.1, Impacts to the Preferred Alternatives, discusses mitigation to the T&E species. Section 5.6 discussed BMPs and other pre-emptive activities to reduce impacts on T&E species and mitigation measure to protect T&E species.

g. Terrestrial and aquatic plant life. Direct impacts to vegetation resources will result from vegetation compaction by construction equipment or surface disturbances such as mechanical grading and clearing of vegetation for the temporary laydown/materials yard and access roads. It is not anticipated that there will be significant removal of vegetation at the base of each transmission structure. Temporary impacts to vegetation will also result in periodic compaction of existing vegetation and soil from construction and maintenance traffic within the transmission line ROW and designated access roads. These impacts will be short-term in duration and focused in location, and the disturbed areas will be re-seeded with approved local, native seed mixes after clearing. Vegetation would be permanently removed at transmission structure locations.

The mitigation for vegetation removal at the base of each structure will match the existing vegetation and may consist of native shortgrass perennial species, cropland, or pasture, as appropriate. A seed bed will be prepared to depth of 3” to 4” and then the seed mix will be spread via broadcast or hydroseeding. A certified seed mix or plugs will be used to re-establish the vegetation in agreement with the recipient landowner.

PAGE 9 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

h. Soils and geologic conditions. The Project will create short-term, localized impacts on soil resources, which could result in the potential reduction of surficial soil quality. Ground disturbance during construction may increase the potential for erosion, such as removal of protective vegetation and expose soil to potential wind and water erosion. Impacts will result from soil disturbance due to heavy machinery traveling along the transmission line ROW. General construction traffic will be limited to designated access roads in an effort to minimize impacts. The areas affected by construction would be reclaimed as soon as possible, which may include regrading to original land contours and revegetation with an approved seed mix. Implementation of a SWPPP and GESC and use of appropriate soil mitigation measures and BMPs would be used to reduce the effects of erosion.

13. The Proposed Project will not cause a nuisance.

There will be an anticipated increase in traffic during the Project’s construction period on local county roads. Given the low-density, sparsely populated area of the county in which the route alternatives would be situated, no substantial impacts would occur to existing and future traffic volumes and Level of Service (LOS). LOS is a qualitative measure used to relate the quality of traffic service. LOS is used to analyze highways by categorizing traffic flow and assigning quality levels of traffic based on performance measures including vehicle speed and volume. LOS is scored using letters from A to F, where A represents the best conditions (free-flow traffic conditions) and F represents failure of the system with excessive delay (failure or breakdown in the traffic system). Roadway corridors that operate at LOS C or better are categorized as uncongested and generally operate in free-flow conditions where drivers can operate at their desired speed without undue delay. Rural roads in Arapahoe County currently operate at a LOC C or better (Arapahoe County 2010a). Roads near the route alternatives would be expected to continue to operate at or above LOS C during and after Project construction activities. Vibration, odors, or other nuisances from the operation and maintenance of the transmission are not anticipated, except for minimal noise associated with equipment operation during construction which will be short-term.

The use of augers and vibration cassions may be used to place transmission structures into the ground. Odors from diesel-driven vehicles or construction equipment may be generated in the immediate vicinity of each transmission structure and for short periods of time during the construction period. The location may vary based upon active construction areas. There may be some diesel emissions at the laydown/storage yards where equipment is used to unload and store materials.

14. The Proposed Project will not significantly degrade areas of paleontological, historic, or archaeological importance.

According to the literature and file searches from the Colorado Office of Archaeology and Historic Preservation cultural resource database, no paleontological resources have been

PAGE 10 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

previously recorded within 1,000 feet on either side of the centerline (a 2,000 foot corridor) of the proposed Preferred Alternative.

The Preferred Alternative crosses one site, the only known site within 1,000 feet of the Alternative. This site is the historic route of the Union Pacific Railroad through Arapahoe County. This resource is considered Eligible for the National Register of Historic Places (NRHP). It is the only cultural resource located along the Preferred Route and the Alternatives in Arapahoe County. No previously identified paleontological resources have been identified in the project area. The Preferred Alternative is a generally low impact route that crosses the lowest number of previously recorded sites.

Alternative C crosses the active Union Pacific railroad bed and is within 1000 feet of the Union Pacific RR Historic Route – a previously used railroad bed. The Preferred Alternative (Alternative A) is approximately four (4) miles from the historic resource at its nearest point. Avoidance of the historic resource is the only mitigation that is appropriate for this resource and impacts to visual resources is only accomplished by distance between the historic resource and the proposed transmission line. The Preferred Route is seen by the Union Pacific RR Historic Route (based on a seen/unseen GIS analysis see Appendix H). Previously recorded sites in the vicinity of the Project corridors in Arapahoe County are summarized below in Table 5-5 from the Application. There are no historic / prehistoric previously recorded sites within 1000 feet of the Preferred Alternative. Six miles of ROW of Preferred Alternative are within an area classified for high potential of archaeological and cultural resource sites.

15. The Proposed Project will not result in unreasonable risk of releases of hazardous materials. In making this determination as to such risk, the Board's consideration shall include:

Construction equipment and operation and maintenance vehicles will be properly maintained to minimize leaks of motor oil, hydraulic fluids, and fuels. During construction, refueling and maintaining vehicles that are authorized for highway travel will be performed off-site at an appropriate facility. A Spill, Prevention, Containment, and Countermeasure (SPCC) Plan will be prepared for the Project and will contain information regarding training, equipment inspection, maintenance, and refueling for construction vehicles, with an emphasis on preventing spills. Please see Section 5.11 Hazards and Emergency Procedures for additional information.

a. Plans for compliance with federal and State handling, storage, disposal and transportation requirements. The SPCC Plan will contain detailed information on the procedures for the handling, storage, disposal and transportation of hazardous materials. See Section 5.11 Hazards and Emergency Procedures for additional information.

b. Use of waste minimization techniques. The SPCC Plan will contain detailed information on waste minimization techniques. In addition, PSCo will use include construction documents that address the

PAGE 11 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

minimization and proper disposal of construction waste materials. Please see Section 5.11 Hazards and Emergency Procedures for additional information.

c. Adequacy of spill prevention and response plans. The SPCC Plan will contain information regarding training, equipment inspection, maintenance, and refueling for construction vehicles, with an emphasis on preventing spills. PSCo will include their standard emergency response plan for spills and emergencies in their project construction documentation. Please see Section 5.11 Hazards and Emergency Procedures for additional information.

16. The benefits accruing to the County and its citizens from the proposed activity outweigh the losses of any resources within the County, or the losses of opportunities to develop such resources.

The Project will present economic and environmental benefits to Arapahoe County, the State of Colorado, and PSCo’s ratepayers, and further, there are limited costs to PSCo associated with the Project. Costs and benefits are summarized below and discussed in Section 5.12 of this application.

Potential Project benefits include: • Increase tax based for Arapahoe County; • Easement payments provide additional income for landowners; • Local spending for Project construction materials and other goods and services; • Economic generation for the State of Colorado for Project construction materials, specialized labor, and other goods and services; • Long-term cost savings for PSCo ratepayers; • County road maintenance and improvements; • Facilitating renewable, sustainable energy for the State of Colorado; and • Support to local community organizations and events.

Potential Projects impacts include: • Visual impacts due to heights of transmission line structures; and • Minimal community and local governmental service demands, including minor impact to emergency, fire, and safety services.

17. The Proposed project is the best alternative available based on consideration of need, existing technology, cost, impact and these regulations.

When considering landowner interests, both within Arapahoe County and along the entire Project route, the selected Preferred Alternative was chosen to minimize impacts to human and natural resources (e.g., habitual structures, wetlands, cultural resources, wildlife, etc.), as it parallels an existing transmission ROW in a sparsely populated, rural area and provides a unencumbered route to the Missile Site Substation The end result was the identification of eight end-to-end alternatives and selection of a Preferred Alternative that balances all the factors necessary to ensure a properly sited transmission line that can be sited on available leased public and private land.

PAGE 12 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

18. The Proposed Project will not unduly degrade the quality or quantity of agricultural activities.

The Project will not have significant effects on agricultural activities. Prime farmland within the Project Area in Arapahoe County is classified as prime farmland if irrigated or prime farmland if irrigated with other conditions (such as if cleared of excess salts). Potential soil impacts to prime farmland from transmission line construction include soil erosion, mixing of topsoil and subsoil, potential loss of topsoil, and soil compaction. Prime farmland within the construction zone may be unavailable to agriculture production during the construction period. Prime farmland would be reclaimed after the conclusion of the construction period, which may include regrading to original land contours, relieving compaction, topsoil replacement, and reclamation to the original vegetative cover or similar species.

Assuming each pole structure footprint is approximately ten (10) square feet (permanent impact); access roads are approximately 12’ wide (temporary impacts), and 13 miles of transmission line ROW and access roads in Arapahoe County. The impacts to agricultural lands in Arapahoe County are: • Permanent impact from transmission structures - approximately 0.04 acres (1,600 square feet); and • Temporary impact from access roads-approximately 19 acres.

19. Cultural Resources. The Proposed Project will not significantly interfere with the preservation of cultural resources, including historical structures and sites, agricultural resources, the rural lifestyle and the opportunity for solitude in the natural environment.

According to the literature and file searches from the Colorado Office of Archaeology and Historic Preservation cultural resource database, no paleontological resources have been previously recorded within 1,000 feet on either side of the centerline (a 2,000 foot corridor) of the proposed Preferred Alternative.

20. Land Use. The Proposed Project will not cause significant degradation of land use patterns in the area around the Proposed Project.

Zoning districts within the Project Area include Agricultural Estate (A-E) and the Agricultural-1 (A-1). However, as discussed below, the Project will not have significant

PAGE 13 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

effects on the agricultural activities, as most agricultural activities, such as ranching and grazing of livestock, are compatible with transmission line corridors.

Although the primary land use activity is farming and ranching, only approximately 30 percent of the area is considered prime farmland if irrigated or prime farmland if irrigated with other conditions (such as if cleared of excess salts) as indicated by NRCS. Prime farmland within the construction zone may be unavailable to agriculture production during the construction timeframe. Prime farmland would be reclaimed at the conclusion of the construction period, which may include regrading to original land contours, relieving compaction, topsoil replacement, and reclamation to the original vegetation cover or similar species.

21. Compliance with Regulations & Fees. The applicant has complied with all applicable provisions of these regulations and has paid all applicable fees.

PSCo will comply with all regulations and all development and application fees to Arapahoe County.

C. Additional Criteria Applicable to Major Facilities of a Public Utility In addition to the general criteria set forth in Section V, Part A, above, the following additional criteria shall apply to major facilities of a public utility:

1. Areas around major facilities of a public utility shall be administered so as to minimize disruption of the service provided by the public utility.

PSCo coordinates with local utilities during the planning and construction of new transmission lines. PSCo intends to continue coordination with transmission and distribution providers in order to ensure minimal service disruptions in the eastern area of Arapahoe County. PSCo will coordinate with the Intermountain Rural Electric Association, Mountain View Electric Association, and Tri-State Generation and Transmission Association on any planned outages associated with the construction of the Project in order to minimize any disruptions to service.

2. Areas around major facilities of a public utility shall be administered so as to preserve desirable existing community and rural patterns.

The Project will not degrade the existing rural land use patterns observed in the eastern area of Arapahoe County. The Preferred Alternative parallels an existing transmission line corridor and eliminates a new corridor across an undeveloped area of Arapahoe County.

3. Where feasible, major facilities of a public utility shall be located so as to avoid direct conflict with adopted local comprehensive, State and regional master plans.

PAGE 14 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

100% of its length through the County. The Plan’s Policy 2.4(a) recognizes that facilities such as the transmission line will be allowed in the Rural Area on a case-by-case basis, except in sensitive development and riparian corridor areas. The transmission line will be located on privately- and state-owned lands. The transmission line will not be constructed in riparian or Sensitive Development Areas identified under the Plan.

In addition, the Project is consistent with Arapahoe County planning and zoning and the Arapahoe County Open Space Master Plan (Arapahoe County 2010b) and will comply with all County regulations and requirements. The transmission line will adhere to Policy PFS 4.2 – Achieve Land Use Compatibility, when Siting Regional and Local Utilities requires utilities to be built in a manner that is safe and compatible with surrounding land uses. Zoning districts within the Project Area include Agricultural Estate (A-E) and Agricultural-1 (A-1). The zoning districts are intended to correspond to and implement the “Rural Area Uses” and “Open Space” land use categories designated in the Land Use Plan element of the Comprehensive Plan. The regulations for A-E and A-1 are district-specific which are applied on a district-wide basis and generally relate back to the stated purposes of the zone district. Please see Section 3.1 for more information.

4. Where feasible, major facilities of a public utility shall be located so as to minimize dedication of new right-of-way and construction of additional infrastructure (e.g., gas pipelines, roads, and distribution lines).

PSCo used best industry standards and extensive experiences from similar projects in planning the Rush Creek 345 kV Transmission Line Project so as to minimize the dedication of greenfield ROW and the construction of new infrastructure beyond that which is already contemplated in CO SB-07-100. The Preferred Alternative will parallel the existing NextEra 345kV transmission line from the Arapahoe/Elbert County line to the Missile Site Substation.

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PAGE 16 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

1. APPLICANT INFORMATION

1.1 Applicant Address and Contact Company: Contact: Public Service Company of Colorado Erin A. Degutis, RLA, AICP, LEED AP 1800 Larimer Street, 4th Floor, Telephone: 303.571.7735 Denver, Colorado 80202 Email: [email protected]

1.2 Background on Xcel Energy, Inc. and Public Service Company of Colorado. Xcel Energy is a major U.S. electric and natural gas company with annual revenues of $11 billion. Based in Minneapolis, Minnesota, the company provides the energy that serving more than 3.3 million electric customers and 1.8 million natural gas customers across eight Western and Midwestern states, including Colorado, Michigan, Minnesota, New Mexico, North Dakota, South Dakota, Texas, and Wisconsin (Figure 1-1).

Xcel Energy’s workforce of more than 12,000 is rising to the challenge of a changing industry— one that requires the company to be even more customer focused, forward thinking and productive. Xcel Energy remains committed to meeting its customers’ fundamental need for safe, reliable, affordable energy.

Xcel Energy is a recognized industry leader in delivering renewable energy and reducing carbon and other emissions, efforts that have put it on a path to a more sustainable energy future. Xcel Energy is proud to be the No. 1 utility wind-generated electricity provider for the 12th consecutive year. Its business requires that it achieves the right mix in all it does—cultivating the right talent, offering customers the right options, collaborating with communities, investing for the future and protecting the environment. PSCo does not own or operate any other wind transmission projects in Colorado. Independent Power Producers (IPPs) own and operate the high voltage transmission lines from their wind farms that connect with PSCo substations. PSCo has a wind portfolio of over 2600 MW, which is purchased through 15 long-term purchase power agreements. PSCo purchases wind energy from the following wind farms in Colorado: Peetz Table; Cedar Creek I and II; Logan; Ridge Crest; Spring Canyon; North Colorado I and II; Cedar Point; Limon I, II, and III; Golden West; Colorado Green; and Twin Buttes. The inclusion of the Rush Creek Wind Project, the largest wind farm in the state when completed, will bring PSCo’s wind portfolio total to over 3200 MW.

Xcel Energy Inc.’s operations include the activity of four wholly owned utility subsidiaries that serve electric and natural gas customers in eight states. These utility subsidiaries, referred to as operating companies, are Northern States Power Company-Minnesota, Northern States Power Company- Wisconsin, Public Service Company of Colorado (PSCo) and Southwestern Public Service Company. PSCo is the subsidiary of Xcel Energy that will own, construction, operate, and maintain the proposed Project that this application is prepared for.

PAGE 17 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Figure 1-1 Xcel Energy Inc. Service Territory (Blue shaded areas)

1.3 Legal Description and Disclosure of Ownership The Applicant, PSCo (the Applicant), is proposing to construct approximately 13.5 miles of 345 kilovolt (kV) transmission line in Arapahoe County (the Project). PSCo is submitting their Areas and Activities of State Interest (1041) permit application per the requirements outlined in Chapter 5 of the Regulations Governing Areas and Activities of State Interest in Arapahoe County for the Project. The Project Area within Arapahoe County is approximately 300 acres. It is PSCo’s intent to secure options for transmission line easements (options) with the landowners within the Project Area prior to the Arapahoe Board of County Commissioners meeting this fall. State lands are crossed for 1 mile in Arapahoe County.

1.4 Project Finances The Rush Creek wind project will save PSCo ratepayers over $800 million of dollar in energy costs over the next 25 years. With the wind farm and transmission facilities, PSCo will invest an estimated $1 billion dollars into the state’s economy including the purchase of 300 Vestas wind turbines which will be manufactured in Brighton, Pueblo, and Windsor, Colorado. The wind farm will provide millions of dollars in sales and property taxes to local and state government and $3 to $7.5 million in annual landowner wind payments. At the peak of construction, the wind and transmission project will employ about 350 construction workers.

The Arapahoe County portion of the Rush Creek 345 kV Transmission Line Project will consist of approximately 13.5 miles of transmission line construction. The construction period in Arapahoe County will be approximately 15 to 20 weeks with various levels of activity occurring simultaneously during that time (see Section 2.4 below).

The total estimated cost to construct the entire 80-93 mile-long (depending on the alternative route selected) transmission Project is approximately $121 million. These costs will initially be paid out of PSCo’s operating capital.

PAGE 18 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

See Appendix G for the overview of PSCo’s financial statement for fiscal year 2015. See pages 12-19 (34-39 page numbering within the file) in the Appendix G for a summary of PSCo’s current finances in terms income, expenses, liabilities, etc. Xcel Energy’s Annual Report for 2015 and the most recent 10-K filing with the Securities and Exchange Commission is available upon request.

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PAGE 20 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

2. PROJECT DESCRIPTION

2.1 Project Purpose and Need The demand for alternative energy sources has steadily increased in the United States and in Colorado. Colorado became the first state to create a RPS by ballot initiative, when voters approved Amendment 37 in November 2004. Through various legislative mechanisms, the RPS has increased in Colorado from three percent in 2007 to 30 percent by 2020. In Title 4 of the Colorado Code of Regulations 723-3, Section 3651 (Overview and Purpose), it states:

Energy is critically important to Colorado’s welfare, and development, and its use has a profound impact on the economy and environment. Growth of the state’s population and economic base will continue to create a need for new energy resources, and Colorado’s renewable energy resources are currently underutilized. Therefore, in order to save consumers and businesses money, attract new businesses and jobs, promote development of rural economies, minimize water use for electricity generation, diversify Colorado’s energy resources, reduce the impact of volatile fuel prices, and improve the natural environment of the state, it is in the best interest of the citizens of Colorado to develop and utilize renewable energy resources to the maximum extent practicable.

From now through 2025, energy demand is expected to grow approximately two percent annually. The Colorado Department of Local Affairs estimates that the state’s population will grow to over 6.7 million people by 2025, a 64 percent increase over the current population. PSCo’s system in Colorado will continue growth at 1.4 percent annually, with approximately 126,000 new customers by year 2023. With population growth projections and energy demand growth, PSCo will need approximately 600 megawatts of additional power supplies through the year 2023. Upon completion, the proposed Rush Creek Wind Project will be the largest wind-generated electricity generation facility in Colorado, contributing significantly to Colorado achieving its renewable energy goals.

2.2 Project Overview PSCo is proposing to develop 600 MW of new wind-generated electricity and approximately 80 to 93 miles (depending on the alternative) of new 345 kV transmission facilities on the eastern plains of Colorado. The wind projects will consist of two wind farms; an approximately 400 MW wind farm called Rush Creek I, located in Elbert County; and an approximately 200 MW wind farm called Rush Creek II, located in Lincoln, Kit Carson, and Cheyenne Counties. Land use permitting and leasing for these two farms will be completed by a wind developer, Invenergy LLC. Upon completion of permitting and leasing of the Rush Creek Wind Farms, PSCo will acquire the Rush Creek I and Rush Creek II Wind Farms from Invenergy LLC and complete development, including construction, operation, maintenance, and ongoing ownership of the farms.

PSCo is proposing to construct a new 345 kV transmission line interconnecting the Rush Creek I and Rush Creek II Wind Farms to the existing Missile Site Substation located in Arapahoe County. The 345 kV transmission line will be approximately 80 to 93 miles (depending on the Preferred Alternative) in length, with a 150 to 200-foot ROW. PSCo’s Preferred Alternative is approximately 81 miles in length and crosses portions of Arapahoe, Elbert, and Lincoln Counties. All three counties will require land use

PAGE 21 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

permits to construct the transmission line. Arapahoe and Elbert Counties will require 1041 and Special Use Permits; Lincoln County will require a Use by Special Review and Development Permit. PSCo filed a Certificate for Public Convenience and Necessity application with the Colorado PUC on May 13, 2016.

2.3 Rush Creek Wind and Transmission Project Overview For background and context for the entire Rush Creek Wind Project, a brief overview of wind-generated electricity and a general overview of the Rush Creek Wind Project are included below. There will be no wind generation facilities in Arapahoe County and this 1041 Permit Application is for the Rush Creek 345 kV Transmission Line.

The basic components of any wind-generated electricity generation facility include the turbines, power collection system, roads, substations or switchyards, and transmission system. Wind-generated electricity production includes the following five basic components,

1. Electrical Power Generation – Wind blowing against the turbine blades causes the blades to rotate, which in turn rotates electrical generators that produce electricity.

2. Energy Transfer – The generated electricity is fed through cables within the tower to a base panel at ground level inside the tower. The electricity is fed to a transformer located in or adjacent to the tower that increases (steps up) the power to a higher voltage.

3. Collection System – The power stepped-up through the transformer is fed into an underground or overhead collection system. Power collection lines connect groups of wind turbines in the field to a substation.

4. Substation/Switchyard – At the substation, the voltage is stepped up again to that it can be fed into the electrical transmission system. At a switchyard, the electric transmission is connected into an existing transmission system of the same size. In Arapahoe County, there will only be upgrades to the existing Missile Site Substation to accommodate the interconnection for this project.

5. Utility Transmission – Electricity is sent through the electrical transmission lines to utility distributions systems for delivery to customers. The proposed 345 kV transmission line will connect to the existing Missile Site Substation in Arapahoe County north of Deer Trail, Colorado.

Table 2-1 Rush Creek Wind Project Overview by County Rush Creek I - 400 Rush Creek II - 200 County 345 kV Transmission Line Substations MW Project MW Project Modify the existing Missile Site Substation Arapahoe ~ 13.5 miles N/A N/A for the proposed 345 kV transmission line interconnection. Cheyenne N/A N/A Yes N/A New collector Elbert ~ 41 miles Yes N/A substation for Rush Creek I. Kit Carson N/A N/A Yes N/A

PAGE 22 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Rush Creek I - 400 Rush Creek II - 200 County 345 kV Transmission Line Substations MW Project MW Project New collector Lincoln ~ 26 miles N/A Yes substation for Rush Creek II.

The Site Plan (Exhibit A) shows a layout of the proposed Rush Creek Wind Project, including the transmission line routing, arrangement of wind turbines, roads, and substations. Engineering design of the entire Rush Creek Wind Project is ongoing; this information is subject to minor changes, including the final transmission line routing and structure placement, substation locations, construction access roads, temporary staging and material yards, number of turbines and the specific locations of turbines, new roads, collection systems, and other associated project facilities.

2.4 Arapahoe County Project Site Description The Arapahoe County – Rush Creek 345 kV Transmission Line Project Map (Figure 2-1) depicts the project location in the eastern area of Arapahoe County. The portion of the Project in Arapahoe County will be sited on private or state lands comprising approximately 300 acres of utility ROW that is between 150 and 200 feet wide. Of the approximately 13.5 miles of proposed transmission line in Arapahoe County, 100 % is co-located with existing transmission line. PSCo will finalize design and layout of the transmission and substation facilities and infrastructure prior to signature of final design that follows approval of 1041 Permit and associated permits (i.e., building permit, etc.) required for the Rush Creek 345 kV Transmission Line Project prior to construction.

The existing Missile Site Substation, owned by PSCo, will be the termination point of the 345 kV transmission line. The Arapahoe County – Rush Creek 345 kV Transmission Line Project Map (Figure 2- 1) and Exhibit A contains a site plan of the proposed facilities in Arapahoe County. The transmission line will extend south from the Missile Site Substation for approximately two miles, then east for approximately three miles, then south across Jolly Road for approximately three miles, then east for approximately two and one-half miles, and then south across Wall Road to the Arapahoe/Elbert County line for approximately three miles. The Arapahoe County portion of the project is characterized by rural and semi- flat to gently rolling topography, with occasional drainages and ravines. The land use of the area is primarily dryland farming and ranching. The land is underlain by loamy soils covered by shortgrass vegetation or agricultural fields. The zoning in the eastern area of Arapahoe County is predominantly Agricultural Estate (A-E) with a few parcels of Agricultural-1 (A-1).

2.5 Transmission Line Siting Overview and Alternative Analysis Summary

2.5.1 Transmission Line Siting Overview The siting of transmission lines is a complex process that must balance the engineering, environmental, and social factors of a project. In the siting of the transmission line for the Rush Creek Wind Project, PSCo first defined and Project Area with endpoints and then undertook a series of studies and analyses to evaluate several transmission line corridors. The criteria for siting was selected to minimize environmental impact, reduce proximity to residences, and meet engineering requirements. The end result was the identification of eight end-to-end alternatives and selection of a Preferred Alternative that

PAGE 23 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03 balances the factors necessary to ensure a properly sited transmission line that can be sited on available public and private land.

Several environmental resources were evaluated relative to the Preferred Alternative and the other identified end-to-end alternatives. These criteria were based on resources that could be quantified along each alternative with readily available data and which were potentially sensitive resources within Arapahoe County. These criteria are included in Table 2-2 below.

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PAGE 28 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Table 2-2 Land Use and Environmental Transmission Line Siting and Analysis Criteria Evaluation Criteria Land Use/Engineering/Construction Length of alternative route Number of Angles Slope of 30% Total number of habitable structures1 within 500 feet & 0.5 miles of ROW centerline Total number of other structures within 500 feet & 0.5 miles of ROW centerline Educational/daycare facilities Churches Medical facilities Other (museums, libraries, commercial etc.) Length of ROW parallel and adjacent to apparent property boundaries2 Length of ROW parallel and adjacent to existing transmission line ROW Length of ROW parallel to other existing right of way (highways, railways, pipelines, etc.) Number of parks/recreational areas3 within 1,000 feet of ROW centerline Length of ROW through cropland Length of ROW through pasture/rangeland Length of ROW through land irrigated by traveling systems (rolling or pivot type) Number of pipeline crossings Number of transmission line crossings Number of railroad crossings Number of Interstate, U.S. and State highway crossings Number of cemeteries within 1,000 feet of the ROW centerline Number of private airstrips within 10,000 feet of the ROW centerline Length of ROW through active sand, gravel or coal extraction area Number of heliports within 5,000 feet of the ROW centerline Number of FAA recognized airports with at least one runway more than 3,200 feet in length located within 20,000 feet of ROW centerline Number of FAA recognized airports having no runway more than 3,200 feet in length located within 10,000 feet of ROW centerline Number of commercial AM radio transmitters within 10,000 feet of the ROW centerline Number of FM radio transmitters, microwave towers, and other electronic installations within 2,000 feet of ROW centerline Aesthetics Estimated length of ROW within foreground visual zone4 of Interstate, U.S. and State highways Estimated length of ROW within foreground visual zone4 of parks/recreational areas³ Ecology Length of ROW across National Wetland Inventory mapped wetlands Length of ROW across known habitat of federally listed endangered or threatened species Length of ROW across known habitat of state listed endangered or threatened species Length of ROW across known habitat of raptor species Acres of ROW that cross major vegetation cover types Length of ROW across open water (lakes, ponds) Length of ROW across playa lakes Length of ROW across FEMA-designated floodplain Number of stream crossings (including perennial, intermittent, and ephemeral streams)

PAGE 29 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Evaluation Criteria Number of river crossings Length of ROW parallel (within 100 feet) to streams or rivers Cultural Resources Number of recorded historic or prehistoric sites crossed by ROW Number of additional recorded historic or prehistoric sites within 1,000 feet of ROW centerline Number of National Register listed or determined eligible sites crossed by ROW Number of additional National Register listed or determined eligible sites within 1,000 feet of ROW centerline Length of ROW through areas of high archaeological/historic site potential Notes: 1 Single-family and multi-family dwellings, and related structures, mobile homes, apartment buildings, commercial structures, industrial structures, business structures, churches, hospitals, nursing homes, schools, or other structures normally inhabited by humans or intended to be inhabited by humans on a daily or regular basis within 500 feet of the centerline of a transmission project greater than 230-kV. 2 Property lines created by existing roads, highway, or railroad ROW are not “double-counted” in the length of ROW parallel to property lines criteria. ³ Defined as parks and recreational areas owned by a governmental body or an organized group, club, or church. One-half mile, unobstructed.

⁴ 2.5.2 Transmission Line Alternatives and Analysis Summary Following collection and analysis of the Environmental Siting Criteria (see Table 2-2 above), a geographic information system (GIS) was used to quantify the siting criteria for each of the eight Alternatives geospatially and select PSCo’s Preferred Alternative. The geospatial quantification for each alternative and those portions occurring in Arapahoe County is summarized below and in Table 2-3. A map of the eight alternatives routes is shown in Figure 2-2 – Transmission Line Alternatives Map.

2.5.2.1 Wetlands Wetland crossings were identified using the National Wetland Inventory (NWI) digital database. This database, established in 1975 by the U.S. Fish and Wildlife Service (USFWS), provides wetlands data in map and digital form for the United States. Each Alternative was overlaid onto the NWI digital database to determine the number of wetlands crossed by each line. In Arapahoe County, Alternatives A, B, D, E, and H do not cross wetlands. Alternatives C, F, and G have the highest total length of NWI wetlands crossed by the ROW in Arapahoe County, with 0.3 miles.

2.5.2.2 Floodplains Arapahoe County floodplains were mapped in GIS using Federal Emergency Management Agency (FEMA) and cross-checked with Arapahoe County’s ArapaMap 3.6 online mapping tool (see Exhibit B – Water Resources – Arapahoe County Map). In Arapahoe County, Alternatives A, B, E, and H do not cross FEMA Floodplains. Alternatives A, B, E, and H do cross seven Arapahoe County defined floodplains (any drainage way with a tributary area of 130 acres or more). Alternatives C, F, and G have the highest total length of FEMA-designated floodplains crossed in Arapahoe County, with 0.8 miles. In Arapahoe County no perennial streams, ephemeral streams, or river are crossed. Alternatives C, F, and G have nine intermittent stream crossings; Alternatives A, B, E, and H have 15 intermittent stream crossings; and Alternative D has 25 intermittent stream crossings.

PAGE 30 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Table 2-3 Arapahoe County Transmission Line Comparison Table Arapahoe County Portion of the Alternative Entire Alternative Environmental Siting Criteria A B C D E F G H A B C D E F G H Length of alternative route (Miles) 13.5 13.5 8.4 22.1 13.5 8.4 8.4 13.5 80.9 82.4 86.0 93.0 87.6 88.0 86.1 84.8 Number of Angles (over 6 degrees) 4 4 11 10 4 11 11 4 34 36 31 34 34 36 37 31 Slope of 30% (Miles) 0 0 0 0 0 0 0 0 0 0 0 0.21 0.04 0 0 0 Total number of residences within 500 feet of right-of-way (ROW) centerline 1 1 1 0 1 1 1 1 5 7 8 2 4 7 6 10 Total number of residences within 0.25 miles of right-of-way (ROW) centerline 4 4 4 2 4 4 4 4 13 15 18 27 13 13 14 18 Total number of residences within 0.5 miles of right-of-way (ROW) centerline 9 9 12 2 9 12 12 9 23 25 35 205 34 62 30 32 Total number of other structures within 500 feet of right-of-way (ROW) centerline 0 0 5 0 0 5 5 0 7 10 19 11 10 25 17 16 Total number of other structures within 0.25 miles of right-of-way (ROW) centerline 4 4 6 0 4 6 6 4 16 22 38 27 29 41 26 33 Total number of other structures within 0.5 miles of right-of-way (ROW) centerline 7 7 11 0 7 11 11 7 46 49 84 155 88 96 68 69 Total number of Educational/daycare facilities within 500 feet of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Educational/daycare facilities within 0.25 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Educational/daycare facilities within 0.5 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Churches within 500 feet of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Churches within 0.25 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Churches within 0.5 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Medical facilities within 500 feet of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Medical facilities within 0.25 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Medical facilities within 0.5 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total number of Other (museums, libraries, commercial etc.) within 500 feet of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 Total number of Other (museums, libraries, commercial etc.) within 0.25 miles of right-of-way (ROW) centerline 0 0 0 0 0 0 0 0 0 0 0 1 0 7 0 0 Total number of Other (museums, libraries, commercial etc.) within 0.5 miles of right-of-way (ROW) centerline 0 0 0 2 0 0 0 0 0 0 0 16 0 10 0 0 Length of ROW parallel and adjacent to apparent property boundaries2 0 0 4.5 0 0 4.5 4.5 0 30.7 29.7 47.7 21.3 35.1 32.0 45.2 31.9 Length of ROW parallel and adjacent to existing transmission line ROW 13.5 13.5 2.2 22.0 13.5 2.2 2.2 13.5 25.3 26.4 2.2 56.2 28.1 20.2 2.2 26.4 Length of ROW parallel to other existing right of way (highways, railways, pipelines, etc.) 0 0 0.3 0.1 0 0.3 0.3 0 9.9 11.8 14.7 7.2 11.3 19.3 16.2 17.2 Number of parks/recreational areas3 within 1,000 feet of ROW centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Length of ROW through cropland 7.3 7.3 4.8 9.4 7.3 4.8 4.8 7.3 13.6 14.4 11.9 16.9 12.5 11.6 12.7 13.5 Length of ROW through pasture/rangeland 5.7 5.7 2.4 12.1 5.7 2.4 2.4 5.7 64.1 65.0 67.9 72.4 70.4 70.2 67.4 67.0 Length of ROW through land irrigated by traveling systems (rolling or pivot type) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of pipeline crossings 4 4 2 4 4 2 2 4 10 10 12 12 14 12 12 10 Number of transmission line crossings 5 5 4 3 5 4 4 5 7 7 5 7 7 7 5 7 Number of railroad crossings 0 0 1 0 0 1 1 0 2 2 2 2 2 2 2 2 Number of Interstate, U.S. and State highway crossings 0 0 1 0 0 1 1 0 5 5 5 4 4 5 5 4 Number of cemeteries within 1,000 feet of the ROW centerline 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 Length of ROW through active sand, gravel or coal extraction area 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of private airstrips within 10,000 feet of the ROW centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of heliports within 5,000 feet of the ROW centerline 0 0 0 0 0 0 0 0 0 0 0 1 0 1 1 0 Number of FAA registered airports with at least one runway more than 3,200 feet in length located within 20,000 feet of ROW centerline 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0

PAGE 31 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Arapahoe County Portion of the Alternative Entire Alternative Environmental Siting Criteria A B C D E F G H A B C D E F G H Number of FAA registered airports having no runway more than 3,200 feet in length located within 10,000 feet of ROW centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of commercial AM radio transmitters within 10,000 feet of the ROW centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of FM radio transmitters, microwave towers, and other electronic installations within 2,000 feet of ROW centerline 0 0 0 0 0 0 0 0 1 1 1 3 1 7 3 1 Length of ROW across state lands 1.0 1.0 0 3.0 1.0 0 0 1.0 7.1 7.1 6.3 12.7 12.2 8.9 6.3 7.5 Estimated length of ROW within foreground visual zone4 of Interstate, U.S. and State highways 0 0 2.2 0 0 2.2 2.2 0 6.7 6.7 6.6 8.7 5.5 9.9 7.4 5.5 Estimated length of ROW within foreground visual zone4 of parks/recreational areas³ 0 0 0 0 0 0 0 0 0 0 0 1.8 0 1.1 0 0 Length of ROW across National Wetland Inventory mapped wetlands 0 0 0.3 0.2 0 0.3 0.3 0 0.5 0.4 1.5 0.4 0.4 1.3 1.5 0.4 Length of ROW across known habitat of federally listed endangered or threatened species 0 0 0 0 0 0 0 0 0 0 0 1.0 0 0 0 0 Length of ROW across known habitat of state listed endangered or threatened species 0 0 0 0 0 0 0 0 2.2 2.2 9.3 7.6 2.8 13.0 9.4 2.0 Length of ROW across known raptor species nest or nest buffer 0 0 0 0 0 0 0 0 1.4 1.7 0 0 0.4 0 0 0.8 Length of ROW across mixed woodland 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Length of ROW across shortgrass prairie 5.7 5.7 2.0 12.0 5.7 2.0 2.0 5.7 62.5 63.4 65.7 71.5 68.3 68.7 65.0 65.3 Length of ROW across eastern plains shrubland 0 0 0.0 0.1 0 0.0 0.0 0 1.4 1.5 1.4 0.2 1.8 0.4 1.6 1.3 Length of ROW across open water (lakes, ponds) 0 0 0 0 0 0 0 0 0 0 0 0.0 0 0 0 0 Length of ROW across playa lakes 0 0 0.4 0.0 0 0.4 0.4 0 0.2 0.2 0.8 0.5 0.3 1.1 0.8 0.3 Length of ROW across FEMA-designated floodplain 0 0 0 0.0 0 0 0 0 0 0 0 0.1 0.0 0 0 0.0 Number of ROW crossings of Arapahoe County floodplains 7 7 8 26 7 8 8 7 ------Number of perennial stream crossings 0.5 0.5 1.1 0.6 0.5 1.1 1.1 0.5 3.2 2.9 6.2 3.7 4.6 6.3 6.0 4.4 Number of intermittent stream crossings 0 0 0 0 0 0 0 0 0.2 0.2 1.0 0.3 0.2 0.2 1.0 0.3 Number of ephemeral stream crossings 0 0 0.8 0.2 0 0.8 0.8 0 1.5 1.0 2.1 1.0 0.7 2.2 2.1 0.6 Number of river crossings 0 0 0 0 0 0 0 0 2 2 4 5 2 4 4 2 Length of ROW parallel (within 100 feet) to streams or rivers 15 15 9 28 15 9 9 15 82 78 76 115 84 90 71 84 Number of recorded historic or prehistoric sites crossed by ROW 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of additional recorded historic or prehistoric sites within 1,000 feet of ROW centerline 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Number of National Register listed or determined eligible sites crossed by ROW 0 0 0 0.2 0 0 0 0 0.4 0.2 1.1 1.5 0.6 1.5 1.1 0.2 Number of additional National Register listed or determined eligible sites within 1,000 feet of ROW centerline 0 0 1 0 0 1 1 0 2 2 4 14 4 7 5 4 Length of ROW through areas of high archaeological/historic site potential 0 0 1 0 0 1 1 0 1 1 7 8 2 9 6 2

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PAGE 34 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

2.5.2.3 Sensitive Developed Areas Arapahoe County Sensitive Development Areas are defined as prairie grasslands, riparian areas, wildlife habitats, and threatened species conservation areas, where development should be carefully evaluated and designed to minimize impacts on the land. Data from National Land Cover, NWI, FEMA floodplains, Colorado Natural Heritage Data, and data for CPW were obtained and crossed checked with the Arapahoe County Comprehensive Land Use Plan to determine the length of each route passing through these habitats. Wetland, floodplain, and stream crossings are summarized in previous subsections. Shortgrass prairie is crossed for two miles along Alternatives C, F, and G; for 5.7 miles along Alternatives A, B, E, and H; and for 12 miles along Alternative D.

2.5.2.4 Conservation Areas Potential Conservation Areas are defined by the Colorado Natural Heritage Program as lands that provide habitat and ecological processes upon which a particular species, suite of species, or natural community depends for its continued existence. Although there are no Potential Conservation Areas bisected by any of the routes within the County, this information is presented to compare the alignment of each route relative to these lands on their approach to Arapahoe County. Each route was overlaid onto digital maps of Potential Conservation Areas and the number of miles traversing these lands was calculated.

2.5.2.5 Residences Residences were identified using aerial photography and reconnaissance-level field data collection. Residences included farm dwellings with outbuildings; a single farm dwelling property consisting of multiple outbuildings constituted a single residence. A residence was considered viable if it had a complete roof, windows, and door(s). Each transmission alignment was buffered by 500 feet, 0.25 miles, and 0.5 miles on each side of the proposed transmission line to determine the number of residences that occurred within three previously mention distance bands from each route. The number of residences occurring within the buffered distance per alternative is summarized below in Table 2-4.

Table 2-4 Number of Residences Occurring within the Buffered Distance per Alternative Number of residences within 500 Number of residences within 0.25 Number of residences within 0.5 Alternative feet of the proposed miles of the proposed miles of the proposed transmission line. transmission line. transmission line. A 1 4 9 B 1 4 9 C 1 4 12 D 0 2 2 E 1 4 9 F 1 4 12 G 1 4 12 H 1 4 9

In Arapahoe County, Alternative D is routed near the fewest residences and Alternatives C, F, and G are routed near the most residences.

PAGE 35 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

2.5.2.6 Prime Farmland Prime farmland is land that has the best combination of physical and chemical characteristics for producing food, feed, forage, fiber, and oilseed crops and is available for these uses and is not urban, built up, or water areas (Natural Resources Conservation Service [NRCS] 2016). The Project Area within Arapahoe County would be located within soils that have been identified as prime farmland, if irrigated or prime farmland, if irrigated with other conditions (such as if cleared of excess salts). Each route was overlaid onto digital soil maps and the number of miles traversing soil types classified as prime, if irrigated farmland and prime farmland, if irrigated with other conditions were calculated.

2.5.2.7 Land Use Existing land uses within the eastern area of Arapahoe County are primarily private land, dryland agriculture, pasture/grazing (rangeland), and associated low density residential or agricultural settlements. In the lower density residential areas across the county, settlements of clustered residences, barns, stables, and other agricultural outbuilding are common. Open space occurs primarily on individual private lands, but also on State Land. Colorado State Land Board-owned (State Land) lands are also leased within Arapahoe County in the Project Area (refer to Land Use, Transportation, and Recreation - Arapahoe County; Exhibit C). The Richmil Ranch Open Space, a 352-acre Arapahoe County open space area, is located just west and outside of the Project Area study corridors.

Existing transmission lines occur within several corridors in the Project Area and terminate or extend from the exiting Missile Site Substation. The Missile Site Substation is the northern extent of the Project Area. One pipeline also occurs with the Project Area in Arapahoe County. There are other no state, county, or local parks within the Project Area (refer to Land Use, Transportation, and Recreation - Arapahoe County; Exhibit C). There are no hiking or biking trails or fishing stream segments identified within the Project Area corridors by the State of Colorado, Arapahoe County, or the Town of Deer Trail.

Goals, Policies, and Strategies are detailed in the Arapahoe County Comprehensive Plan and address the basic policy direction for the County for eight distinct categories: Growth Management; Public Facilities and Services; Neighborhoods and Housing; Employment and Commercial Development; Transportation; Natural and Cultural Resources and the Environment; Open Space, Parks, and Trails; and Fiscal and Economic Impacts.

Countywide policies and Public Facilities and Services policies specifically apply to the development of a high-voltage transmission line. As defined by the Arapahoe County Comprehensive Plan, Public Facilities include “utility lines,” power substations, and power energy facilities. The Arapahoe County Land Development Code (ACLDC) identifies and establishes the zoning districts for the unincorporated portions of Arapahoe County, and details the regulations specific to each zone. The Zoning Districts are intended to correspond to and implement the “Rural Area Uses” and “Open Space” land use categories designated in the Land Use Plan element of the Arapahoe County Comprehensive Plan. Zoning districts within the Project Area include Agricultural Estate (A-E) and the Agricultural-1 (A-1). The regulations for A-E and A-1 are district-specific which are applied on a district-wide basis and generally relate back to the stated purposes of the zone district.

The A-E Zoning District’s specific purpose is:

PAGE 36 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

• All development in the district must respect and respond to the district’s unique agricultural and rural character, as well as its topography. All development must be sited to avoid or mitigate any adverse impacts on the rural environment and sensitive development areas, including impacts on the Rural Area’s important riparian corridors that perform important drainage, habitat, and recreational functions.

• All development must have no detrimental effects on soil stability or ground water supplies, and all development must also mitigate impacts from runoff or from changes to the drainage characteristic of the land.

The A-1 Zoning District’s specific purpose is:

• The A-1 Zoning District is intended to provide and preserve land for agricultural and rural economic uses in the Rural Area of unincorporated Arapahoe County as designated in the Comprehensive Plan. The primary uses allowed in this district are agricultural and open land uses, agriculture-dependent or agriculture-related uses, and other uses supportive of a rural, agriculture-based economy.

The agricultural zoning districts were established to promote and preserve a rural, agricultural economic base, and lifestyle in the eastern areas of unincorporated Arapahoe County. Residential uses are secondary in the agricultural districts and are developed at very low densities or clustered to protect and conserve existing open and agricultural lands as well as to preserve a rural character. Major Electrical, Natural Gas, and Petroleum-Derivative Facilities of a Private Company are considered an allowed Use by Special Review (USR) in the ACLDC. Refer to Exhibit D (Zoning, Special Districts and Parcels – Arapahoe County Map) for zoning districts within the County.

2.5.3 Selection of the Preferred Alternative When considering landowner interest, both within Arapahoe County and along the entire transmission line route, the selected Preferred Alternative was designed to balance minimizing the number of residences passed along the route within Arapahoe County, minimizing the distance passed through sensitive environmental areas, and minimizing impacts to various resources while maximizing engineering design optimization and the purpose and need of the Project. Alternative A is the shortest end-to-end alternative, it would pass by the fewest number of residences within 0.25 and 0.5 miles (13 and 23 residences, respectively), and has the third lowest number of residences within 500 feet. Alternative A would avoid Potential Conservation Areas and would have the fewest number of wetland crossings. The entire length of Alternative A within Arapahoe County would rank second with respect to the number of stream

PAGE 37 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

crossings. Alternative A within Arapahoe County would have negligible impacts to potential prime farmland soils through the implementation of BMPs; these soils are only considered prime if irrigated.

After reviewing the various resource categories relative to each route alternative through Arapahoe County, Alternative A was selected as the Preferred Alternative. Alternative A would be the second longest alternative through Arapahoe County; however, it would minimize impacts to several key resources and would parallel the existing NextEra 345 kV Transmission Line for its entire length in Arapahoe County. The Preferred Alternative would pass by the fewest number of residences within 1,000 feet and crosses the fewest number of wetlands and floodplains, as defined by Arapahoe County through FEMA data. The Preferred Alternative would rank second for the number of stream crossings and the number of miles through Arapahoe County Sensitive Development Areas; three miles of the preliminary selected route in Arapahoe County were relocated to the west to avoid riparian habitat areas associated with the Muddy Creek drainage. The Preferred Alternative would pass through the most miles of potential prime farmland; however, soils comprising these lands are considered only potential prime farmland and are classified as prime if they are irrigated. The Preferred Alternative would rank second for miles passing through agricultural cropland lands and shortgrass prairie.

In summary, to accommodate landowner interest while seeking to minimize environmental impacts, Alternative A was selected as the Preferred Alternative for this balance based on the analysis compared to the other seven alternatives. Alternative A is compliant with the Arapahoe County Comprehensive Plan, it minimizes impacts to residents, natural resources, and cultural resources and it parallels an existing transmission line corridor for 100% of its length through the County. Similar minimization principals also apply to Alternative A from an end-to-end perspective (Table 2-3).

2.6 Project Features

2.6.1 Transmission Line

2.6.1.1 Structures The proposed transmission structure types for the 345 kV transmission line would be single-circuit steel H-frame and three-pole steel angle structures (see Figures 2-3 and 2-4). Transmission pole structures would be Core-ten (self-weathering) steel, which weathers to a dark chocolate brown color. In some areas, steel transmission structures would be guyed to provide additional structure support. In areas that require long spans between structures, such as riparian or stream crossings, or rugged terrain, a taller, larger H-frame structure would typically be used. In areas where the line changes direction resulting in a greater angle, the transmission line could be supported by three-pole steel angle transmission structures.

PAGE 38 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Figure 2-3 Typical Steel H-Frame Transmission Structure

PAGE 39 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Figure 2-4 Typical Steel Three-Pole Angle Transmission Structure

PAGE 40 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Typical transmission structure heights for the tangent (structures that hold the line up, but bear little tension), dead-end (structure that bears tension) and angle transmission structures (structure that supports change in line direction and bears tension) would be approximately 80 to 130 feet above the existing ground, depending on terrain and span length. Structures spans would typically be 600 to 900 feet in length. In most cases, transmission structures would be directly embedded into the ground. Additional foundation support, such as drilled pier concrete foundations, is not anticipated at this time, but may be used in special design cases depending on geotechnical conditions. The diameter of the transmission structure poles would be approximately three to five feet, depending on framing configuration and the angle to adjacent transmission structures.

2.6.1.2 Conductors and Associated Hardware The 345 kV transmission line would consist of three phases with each phase consisting of bundled conductors composed of two 954 aluminum conductor steel supported (ACSS) cables or conductors of comparable capacity. An ACSS consists of seven steel wires surrounded by 54 aluminum strands. Each conductor is approximately 1.2 inches in diameter. Minimum conductor height above the ground for the 345 kV transmission line would be 30.3 feet, at 167 degrees Fahrenheit based on National Electrical Safety Code (NESC) standards and PSCo’s standards. At road crossings, minimum clearance would typically increase to approximately 37.3 feet above ground.

2.6.1.3 Fiber Optics Fiber optic ground wire (OPGW) cable for substation-to-substation control would be installed on top of each transmission structure in the shield wire. The outer strands would consist of aluminum wire and the entire OPGW would be approximately 0.55 inch in diameter. The OPGW would be reserved for use by PSCo only.

PSCo will install a series of swan diverters on the shield wire, matching the location and spacing of the swan diverters on the adjacent NextEra 345 kV transmission line. Each swan diverter is made of a pre- formed ¼-inch diameter PVC coil that is light gray to white in color. Swan diverters enable raptors and waterfowl to see the shield wire and subsequently avoid collisions. Swan diverters are used by PSCo as an element of the Company’s adopted Avian Protection Plan to reduce collisions and injury with transmission and distribution infrastructure by raptors and waterfowl (EDM International 2003).

2.6.2 Substations The existing Missile Site Substation is the substation directly associated with the proposed transmission line in Arapahoe County. The proposed transmission line will interconnect to the Missile Site Substation in the south central portion of the existing site (see Figure 2-5). The Transmission line will connect to step- down infrastructure in an available empty bay within the substation. The substation perimeter fence will be moved to accommodate the interconnection with the Rush Creek 345 kV Transmission Line.

2.6.3 Right-of-Way Acquisition Easements for the transmission line ROW, temporary work areas, and temporary access roads would be required for the transmission line. Some public road upgrades may be necessary and will be negotiated

PAGE 41 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

through the County Road Transportation Division and private landowners. Transmission line facilities on private lands would be obtained as perpetual easements.

ROW width would vary from 150 to 200 feet, depending on the structure type, terrain, span, and other factors. A 150-foot wide ROW would be required for the typical H-frame and a three-pole angle and guyed structures may require upwards of 200 feet for ROW.

2.6.4 Access Roads The Project would use existing roads and overland travel wherever feasible for access in order to minimize new disturbance. The Project follows an existing utility corridor for 100% of the portion of the transmission line in Arapahoe County. Some new permanent or temporary access/short spur roads may be required to access structure locations within the ROW. New access roads within the existing ROW would retain access for maintenance. Portions of existing access roads located outside of the proposed ROW may require improvements as well as new access roads (temporary or permanent). To minimize ground disturbance and/or reduce visual contrast of the landscape, the alignment of any new temporary access roads or cross-country routes would follow the landform contours in designated areas where practicable, providing that such alignment does not impact other resource values additionally. All temporary access roads would be revegetated with native grasses and forbs following construction. Where ground disturbance is substantial, surface preparation and reseeding would occur. The method of restoration would normally consist of loosening the soil surface, reseeding, installing cross drains for erosion control, placing water bars in the former access road, and filling temporary ditches and swales.

All new access that is not required for maintenance would be closed with concurrence of the landowner or land manager. Gates, where present or if installed, would be closed and/or locked, depending on the agreement with each landowner. Access roads on private property may be maintained with mutual consent of the landowner.

2.6.5 Laydown / Material Staging Areas One to two temporary laydown / material staging areas will be required to store materials and equipment and to assemble structures for the duration of construction of the Project, with the potential of one site at the Missile Site Substation. Each site would be approximately 20 acres in size, located at level areas in close proximity to existing roads within the Project Area. The laydown / staging areas would be used to store material and equipment prior to delivery to the structure sites, park vehicles, and possibly for locating a portable construction trailer. The staging areas would be surveyed for environmental impacts, and if any are found, the staging areas would be relocated or shifted to avoid such sensitive areas. The staging areas would be revegetated and reclaimed after completion of the Project. Confidential negotiations are ongoing with landowners to locate temporary staging areas on private lands and adjacent to public roads. PSCo will provide the locations of the temporary staging areas to the County at the time of construction permit submission.

2.6.6 Protection of Private Property and Resources Existing improvements would be repaired or replaced if they are damaged by construction activities. All existing roads would be left in a condition equal to their condition prior to the construction of the transmission line.

PAGE 42 PAWNEE PAWNEE PAWNEE

Figure 2-5 Missile BRICK CENTER DANIELS PARK CEDAR POINT Site Substation Interconnection EXISTING FENCE

LIMON PROPOSED FENCE SMOKY HILL DANIELS PARK (NEXTERA ENERGY) RUSH CREEK INTERCONNECTION POINT Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

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PAGE 44 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Fences and gates would be installed, or repaired and replaced (if they are damaged by construction activities) to their original conditions as required by the landowner. Temporary gates would be installed only with the permission of the landowner and would be restored to original condition following construction. Gates would be closed and locked, depending on the agreement with the private landowners.

Prior to construction, all supervisory construction personnel would be instructed on the protection of ecological resources. To assist in this effort, the construction contract would address: (a) federal, state, and local laws regarding wetlands, vegetation, and wildlife; (b) the importance of these resources and the purpose and necessity of protecting them; and (c) methods for protecting sensitive resources.

All waste products, including food garbage, from construction sites would be deposited in a covered waste receptacle, or removed daily. Garbage would be hauled to a suitable and appropriately permitted disposal facility.

To minimize the amount of sensitive features disturbed in designated areas, transmission pole would be located during the engineering design process so as to avoid sensitive features such as, but not limited to, riparian areas and watercourses and/or to allow conductors to clearly span the features, within limits of standard pole design.

2.7 Construction Activities The proposed Rush Creek 345 kV Transmission Line Project will use standard construction and operation procedures used for other transmission projects in the western United States. The construction of the Project in Arapahoe County is expected to take approximately 15 to 20 weeks. It is expected that approximately 40 people will be required for the transmission line construction effort. The Project’s construction schedule has activity commencing in the first quarter of 2017 and concluding the second quarter of 2018. The Rush Creek Wind farm will be commissioned in October 2018 and in full operation in December 2018.

2.7.1 Transmission Line Construction

2.7.1.1 Sequence of Activities After landowner easement permission has been granted, the construction of the Project would follow the sequence of: 1) new structure locations surveyed and staked; 2) access roads improved or built where necessary; 3) laydown/materials yard and work areas cleared as needed; 4) materials distributed along centerline; 5) structure holes dug and poles framed and erected; 6) conductors installed; and 7) the site would be cleaned-up and reclaimed. The timing of construction activities may occur at different locations throughout the construction process. This may require several crews operating simultaneously at different locations.

Temporary work/material staging areas would be located on existing disturbed areas or other areas on private lands along the line route with negotiated access rights from private landowners. The yards would serve as field offices, reporting locations for workers, parking space for vehicles and equipment, or sites for temporary marshalling of construction materials.

PAGE 45 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

2.7.1.2 Surveying Construction survey work for the proposed Project consists of ascertaining soil and geotechnical conditions for foundations, specific pole locations and delineation of ROW and work area boundaries, and, in some areas, roads to access work areas.

2.7.1.3 Access Road Construction The Project would be located in close proximity to many public roads in order to access the Project corridor ROW. The construction of temporary construction access roads or overland travel may be required to allow access of construction equipment in the transmission line corridor. This may involve clearing vegetation and crushing vegetation for overland travel. In construction areas where re-contouring is not required, disturbance would be limited to overland driving, where feasible, to minimize changes in the original contours. Large rocks and vegetation may be moved within these areas to allow vehicle access.

Equipment to construct the access roads would include hand tools, bulldozers, and graders. Specific actions would be implemented to reduce construction impacts. Standard design techniques such as installing water bars and dips to control erosion would be included. In addition, measures would be taken to minimize impacts such as rutting and soil compaction in specific locations and during certain periods of the year.

2.7.1.4 Structure Holes Excavations for structure holes would be generally made with truck mounted power auger equipment or a standard sized backhoe or large excavator. Where the soil and geotechnical conditions permit, a truck- mounted power auger would be used. The foundation excavation and installation requires equipment access to the foundation sites. Structure hole excavation and installation require access to the site by a power auger or drill, a crane, and material trucks.

Structure holes left temporarily open or unguarded during construction would be covered and/or fenced where practical to protect the public, livestock, and wildlife. Soil removed from foundation holes would be stockpiled on the work area and used to backfill holes. All remaining soil not needed for backfilling would be spread on the work area or removed from the site.

2.7.1.5 Structure Framing and Assembly Steel pole sections and associated hardware would be shipped to each laydown/materials yard site by truck. Steel structures would be assembled off-site and transported to the appropriate pole locations by truck or helicopter. Insulator strings and stringing sheaves are installed at each ground wire and conductor position while the pole is on the ground. Stringing sheaves (pulleys) are used to guide the conductor during the stringing process for attachment onto the insulator strings. The assembled pole would then be hoisted into place by a crane. Helicopter assisted construction may be utilized for portions of the line.

PAGE 46 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

2.7.1.6 Conductor Installation Once structures are in place, a pilot line would be pulled (strung) from structure to structure and threaded through the stringing sheaves on each insulator. A larger diameter, stronger line would then be attached to the pilot line and strung. This is called the pulling line. This process is repeated until the ground wire and conductor is pulled through all insulator sheaves.

Conductor would be strung using powered pulling equipment at one end and powered braking or tensioning equipment at the other end. For public protection during wire installation, guard structures would be erected over roadways, transmission and distribution lines, structures, and other obstacles. Guard structures would consist of H-frame poles temporarily placed on either side of an obstacle. These structures prevent ground wire, conductor, or equipment from falling on an obstacle. Equipment for erecting guard structures includes augers, line trucks, pole trailers, and cranes. Guard structures may not be required for small roads. On such occasions, other safety measures such as barriers, flagmen, or other traffic control devices would be used.

Conductor splicing would be required at the end of a conductor spool or if a conductor is damaged during stringing. The work would occur on work areas for the poles or pulling/tensioning sites.

2.7.1.7 Helicopter Use Access is required to each transmission structure site for construction activities, and helicopters may be used to support construction activities on unique areas of the Project that limit vehicle access. Project construction activities potentially facilitated by helicopters may include:

• Transport of equipment and materials to transmission structure sites • Transmission structure placement • Hardware installation • Wire and conductor stringing operations

All helicopter operations would be coordinated with and approved by the FAA.

2.7.1.8 Construction Waste Disposal Construction sites, laydown and material storage yards, and access roads would be kept in an orderly condition throughout the construction period. Refuse and trash would be removed from the sites and disposed in an approved manner. Oils and fuels would be hauled to an approved site for disposal. No open burning of construction trash would occur at any time.

2.7.1.9 Site Reclamation Work sites would be reclaimed using excess materials, native vegetation, and topsoil stockpiled for that purpose. The contractor would dispose of excess soil materials, rock, and other objectionable materials that cannot be used in reclamation work.

Disturbed areas, with the exception of access roads, would be reclaimed, to the extent possible, to their original contour and reseeded where appropriate. Ripping and other surface scarification on construction roads or other areas would be done as necessary. In some cases the amount of soil compaction and

PAGE 47 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

vegetation destruction may not warrant ripping and reclamation. This would be determined on a case-by- case basis.

2.8 Operation and Maintenance

2.8.1 Permitted Uses After the constructed transmission line has been energized, land uses compatible with safety regulations, operation and maintenance (O&M) would be permitted within and adjacent to the ROW. Existing land uses such as agriculture and grazing are generally permitted within the ROW. Incompatible land uses include construction of permanent dwellings and any use requiring changes in surface elevation that would affect NESC electrical clearances of existing or planned facilities.

Safety is PSCo’s primary concern in the planning and design of this transmission line. An AC (alternating current) transmission line would be protected with power circuit breakers and related line relay protection equipment. If a conductor failure occurs, power would be automatically removed from the line. Lightning protection would be provided by overhead static and grounding wires along the length of the line. All fences, metal gates, pipelines, etc., that cross or are within the transmission line ROW would be grounded to prevent electrical shock and to meet NESC requirements.

2.8.2 Maintenance Maintenance of the transmission line would be performed as needed. When access is required for non- emergency maintenance and repairs, PSCo would adhere to the same precautions taken during the construction activities. PSCo routinely contacts landowners when it needs access to their lands for maintenance activities on transmission lines.

Emergency maintenance would involve prompt movement of crews to repair or replace any damage. Crews would be instructed to protect vegetation, wildlife, and other environmental resources to the extent possible. Reclamation procedures following completion of repair work would be similar to those prescribed for normal construction. Limiting noise, dust and the danger caused by maintenance vehicle traffic provide for the comfort and safety of local residents.

2.9 Traffic Safety Minimal additional vehicular traffic will occur on public roads in the portions of the Project area located in Arapahoe County as a result of construction and O&M of the transmission line. Estimated construction traffic during the construction phase of the transmission line will be approximately 12 to 22 vehicles per day. Because of the low number of vehicles needing access to the transmission line minimal impacts are anticipated. The transmission line would not cross U.S. or State highways in Arapahoe County. County road use and crossings in Arapahoe County would be coordinated with the County Transportation Division and additional details are included in Appendix C – Draft Arapahoe County Road Use Agreement

PAGE 48 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

2.10 Agency Coordination PSCo has coordinated with several federal, state, and local agencies and other entities throughout the planning process for the transmission line in Arapahoe County. In Appendix D – Agency Correspondence, there are correspondence documents showing coordination with the relevant agencies. Entities coordinated with include:

• Arapahoe County Engineer • Arapahoe County Public Works and Development, Planning Division • Colorado Department of Transportation • Colorado State Land Board • Colorado Parks and Wildlife • Colorado State Historic Preservation Office • Federal Aviation Administration • U.S. Army Corps of Engineers • U.S. Fish & Wildlife Service • Colorado Cattleman’s Association • Colorado Farm Bureau

The federal, state, and county permits, approvals or consultations required for the project are summarized below is Table 2-5

Table 2-5 Major Permits, Approvals, and Consultations for the Project Agency Permit/Approval/Consultation Federal US Army Corps of Engineers Clean Water Act Section 404 Permit (Nationwide Permit 12) National Pollution Discharge Elimination System US Environmental Protection Agency Compliance through Arapahoe County US Fish and Wildlife Service Avian Protection Plan for Transmission Lines US Fish and Wildlife Service Bald and Golden Eagle Protection Act Compliance US Fish and Wildlife Service Endangered Species Act Compliance US Fish and Wildlife Service Migratory Bird Treaty Act Compliance State Colorado Department of Public Health and Stormwater Pollution Prevention Plan General Permit and Environment – Water Quality Control Division NOI / CWA Section 401 Water Quality Certification Colorado Department of Agriculture Noxious Weed Act Compliance Colorado Department of Transportation Road Use Agreement through Arapahoe County Colorado Office of Archaeology and Historic Historical, Prehistorical, and Archaeological Resources Act Preservation of 1973 (CRS 24-80-401 to 410) Compliance Colorado Non-game, Endangered, and Threatened Colorado Parks and Wildlife Conservation Act compliance/Senate Bill (SB) 40 Certification for impacts to SB 40 jurisdictional streams County Public Works and Development, Planning Areas and Activities of State Interest/1041 Land Use Permit Division and Special Use Permit Public Works and Development, Planning Grading, Erosion, and Sediment Control Plan Division Public Works and Development, Engineering Floodplain Delineation Study/Floodplain Development

PAGE 49 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Agency Permit/Approval/Consultation Services Division Permit Public Works and Development, Engineering Street Cut and Right-of-Way Use permit Services Division Public Works and Development, Planning Road Use Agreement Division Public Works and Development, Planning Access and Traffic Control Plan Division Public Works and Development, Planning Spill, Prevention, Control and Countermeasure Plan Division (SPCC) Arapahoe County Comprehensive Plan and Arapahoe Public Works and Development, Planning County Land Development Code for land use/zoning Division Compliance

PAGE 50 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

3. REGULATORY FRAMEWORK

PSCo will obtain and comply with the required approvals necessary from county, state, and federal regulatory authorities for the construction, operation, and maintenance of the Project in Arapahoe County. PSCo will obtain Arapahoe County land use, building, and grading, erosion, and sediment control permits in connection with the construction, operation, and maintenance of the proposed transmission line. Material permits applicable to the transmission line in Arapahoe County will include state level permits for stormwater discharge, air (fugitive dust), utility, and oversized load permits. PSCo anticipates that a Nationwide permit under the CWA from the United States Army Corps of Engineers (USACE) will be required.

3.1 Conformance with Arapahoe County Land Use Plans The existing substation and the transmission line are the only elements of the Rush Creek Wind Project located in Arapahoe County. Planning and development goals, policies and strategies detailed in the Arapahoe County Comprehensive Plan (Arapahoe County 2001) address policy direction for the County under eight distinct categories: Growth Management; Public Facilities and Services; Neighborhoods and Housing; Employment and Commercial Development; Transportation; Natural and Cultural Resources and the Environment; Open Space, Parks, and Trails; and Fiscal and Economic Impacts. Each category has goals and is supported by a set of policies and strategies with specific measures to carry the Plan forward. Countywide policies and Public Facilities and Services policies specifically apply to the development of a high-voltage transmission line. As defined by the Arapahoe County Comprehensive Plan, Public Facilities include “utility lines”, power substations, and power energy facilities.

Arapahoe County Comprehensive Plan Countywide Policy GM 2.4 - Allow Development of Public Facilities, Strategy 2.4(a) - Evaluate Public Facilities on a Case-by-Case Basis recognizes that facilities such as the transmission line will be allowed (see Use by Special Review, Arapahoe County Development Code) throughout the county, including in the Rural Area applicable to the Project, except in sensitive development and riparian corridor areas.

Within the Public Facilities and Services category, Policy PFS 4.2 – Achieve Land Use Compatibility, when Siting Regional and Local Utilities requires utilities to be built in a manner that is safe and compatible with surrounding land uses. Strategy PFS 4.2(c) - Require Mitigation of Impacts from Regional Utilities requires mitigation of impacts “on property owners and residents of the county.

The ACLDC identifies and establishes the zoning districts for the unincorporated portions of Arapahoe County, and details the regulations specific to each of the districts. Zoning districts within the Project Area include Agricultural Estate (A-E) and Agricultural-1 (A-1). The zoning districts are intended to correspond to and implement the “Rural Area Uses” and “Open Space” land use categories designated in the Land Use Plan element of the Comprehensive Plan. The regulations for A-E and A-1 are district-specific which are applied on a district-wide basis and generally relate back to the stated purposes of the zone district.

The agricultural zoning districts were established to promote and preserve a rural, agricultural economic base and lifestyle in the eastern parts of unincorporated Arapahoe County. Rural residential uses are secondary uses in these districts, and are developed at very low densities or clustered to protect and

PAGE 51 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

conserve existing open and agricultural lands and to preserve a rural character. Major Electrical, Natural Gas, and Petroleum-Derivative Facilities of a Private Company are considered an allowed use by special review in the ACLDC. Please refer to Exhibit D - Zoning, Special Districts and Parcels – Arapahoe County Map for zoning districts within the County.

The Project has been designed to minimize impacts on land crossed in Arapahoe County. The proposed Project is consistent with Arapahoe County planning and zoning and will comply with all County regulations and requirements.

PAGE 52 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

4. ENVIRONMENTAL RESOURCES: EXISTING CONDITIONS

4.1 Land Use and Recreation This section describes land uses, public recreation, and agency planning and zoning in the Project Area. Land use planning in Colorado is implemented at the county and local level through comprehensive or master plans. C.R.S. 30-28-106 authorizes counties to adopt master plans and details the content to be included. The Project Area generally includes a two-mile wide corridor for greenfield alternatives and a ½- mile wide corridor in areas adjacent to existing transmission lines. Data for the Arapahoe County land use, recreation, and planning analysis was drawn from various sources, including the following:

• Arapahoe County Comprehensive Plan and Amendments (Arapahoe County 2001) • Arapahoe County Open Space Plan Master Plan (Arapahoe County 2010b) • Arapahoe County Development Code (Arapahoe County 2016) • Arapahoe County Open Spaces Website • Colorado Park and Wildlife Website • Colorado State Board of Land Commissioners Geographic Information System Web Mapping Application • Colorado State Fishing Atlas Website, Colorado Parks and Wildlife • Colorado Parks and Wildlife Website • National Land Cover Database (NLCD 2011)

4.1.1 Existing Conditions Land use in the Project Area region is largely agricultural and ranching related (rangeland). Irrigated cropland occurs in very limited areas, with cultivated dryland agriculture being most prevalent. Residences associated with farms and ranches are dispersed across the region. More concentrated development occurs within incorporated and unincorporated population centers west of the Project area. Incorporated municipalities within Colorado include statutory towns, home rule municipalities, consolidated cities, statutory cities and unincorporated towns. Incorporated areas in the eastern area of Arapahoe County include Deer Trail and Bennett. Conservation easements restrict development on many private parcels, and are often located adjacent to publicly owned unique or sensitive natural areas. Colorado State Land Board-owned (State Land) is also leased for agricultural activities.

For the purposes of this study, existing land use was based on field review and the land cover classifications identified by the NLCD. The NLCD land classifications identified within the Project Area are predominantly Grassland/Herbaceous, Pasture/Hay, Shrub/Scrub, and Cultivated Crops. Small areas of other classifications, such as Deciduous forest, Herbaceous and Woody Wetlands, and other (undeveloped) classes are assumed to be used for grazing or ranching (“rangeland”) because these areas occupy a small percentage of total land cover, are generally scattered and patchy except along riparian corridors, and because the most of private land in the area that is not cultivated is used for grazing cattle. Refer to Land Use, Transportation and Recreation – Arapahoe County Map, Exhibit C showing rangeland land uses, and Section 4.6 Biological Resources for more detailed vegetation community descriptions.

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Utility scale wind development and other power generating facilities occur within the region (i.e., Limon Wind #1, #2 & #3, Cedar Point, and Golden West). Oil and gas wells and associated pipelines occur throughout eastern Colorado. Private air strips, airports, and heliports typically associated with institutional or agricultural operations, and communication towers also occupy limited areas of land.

Existing land uses within the eastern area of Arapahoe County are primarily private land, dryland agriculture and pasture/grazing (rangeland), and associated low density residential. In the lower density residential areas across the county and outside of Deer Trail, barns, stables, and other agricultural outbuilding are common. The Town of Deer Trail has the highest development concentration within the Project Area and is developed with residential and commercial land uses, primarily. The Town of Deer Trail is located approximately 0.5 miles south and west of the Project. Open space occurs primarily on individual private lands, but also on State Land. Colorado State Land Board owned (State Land) lands are also leased within Arapahoe County in the Project Area (refer to Exhibit C - Land Use, Transportation, and Recreation - Arapahoe County Map).

Existing transmission lines occur within several utility corridors in the Project Area terminating or extending from the exiting Missile Site Substation. The transmission lines within the Project Area include the Missile Site to Limon 230 kV Transmission Line, Missile Sub To Smoky Hill (West) 345 kV, Missile Sub To Daniels Park Sub 230 kV, Pawnee Plant - Brick Center Sub 230 kV, Pawnee Sub To Missile Sub (East) 345 kV, Pawnee Plant - Brick Center Sub 230 kV, Pawnee Plant-5457 - Missile Substation 230 kV, Cedar Point 2 to Missile Site 345 kV. The Missile Site Substation is also located within the Project Area.

Richmil Ranch Open Space, a 352-acre Arapahoe County open space area, is located west and outside of the Project Area corridors. The privately owned Deer Trail Rodeo Grounds is located within the Town of Deer Trail and within the Project Area. There are no other state, county, or local parks within the Project Area in Arapahoe County (refer to Exhibit C - Land Use, Transportation and Recreation- Arapahoe County Map). There are no hiking or biking trails, or fishing stream segments identified within the Project Area corridors by the State of Colorado, Arapahoe County, or the Town of Deer Trail.

Goals, Policies and Strategies Goals, Policies and Strategies are detailed in the Arapahoe County Comprehensive Plan addressing the basic policy direction for the County under eight distinct categories:

• Growth Management;

• Public Facilities and Services;

• Neighborhoods and Housing; • Employment and Commercial Development;

• Transportation;

• Natural and Cultural Resources and the Environment; • Open Space, Parks, and Trails; and

• Fiscal and Economic Impacts.

Each category includes a set of goals. Each goal is supported by a set of policies and strategies with specific measures to carry the Plan forward. Countywide policies and Public Facilities and Services

PAGE 54 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

policies specifically apply to the development of a high-voltage transmission line. As defined by the Arapahoe County Comprehensive Plan, Public Facilities include “utility lines”, power substations, and power energy facilities.

Relevant Arapahoe County policies for the Project in include:

• Arapahoe County Comprehensive Plan Countywide Policy GM 2.4 - Allow Development of Public Facilities

o Strategy 2.4(a) - Evaluate Public Facilities on a Case-by-Case Basis recognizes that facilities such as the transmission line will be allowed (see Use by Special Review, Arapahoe County Development Code) throughout the county, including in the Rural Area applicable to the Project, except in sensitive development and riparian corridor areas.

• Within the Public Facilities and Services category, Policy PFS 4.2 – Achieve Land Use Compatibility when Siting Regional and Local Utilities requires utilities to be built in a manner that is safe and compatible with surrounding land uses.

o Strategy PFS 4.2(c) - Require Mitigation of Impacts from Regional Utilities requires mitigation of impacts “on property owners and residents of the county”.

Zoning Districts The ACLDC identifies and establishes the zone districts for the unincorporated portions of Arapahoe County, and details the regulations specific to each of the districts. Zoning districts within the Project Area include Agricultural Estate (A-E) and the Agricultural-1 (A-1). The Zoning Districts are intended to correspond to and implement the “Rural Area Uses” and “Open Space” land use categories designated in the Land Use Plan element of the Comprehensive Plan. The regulations for A-E and A-1 are district- specific which are applied on a district-wide basis and generally relate back to the stated purposes of the zone district.

The agricultural zoning districts were established to promote and preserve a rural, agricultural economic base and lifestyle in the eastern area of unincorporated Arapahoe County. Rural residential uses are secondary in these districts, and are developed at very low densities or clustered to protect and conserve existing open and agricultural lands and to preserve a rural character. Major Electrical, Natural Gas, and Petroleum-Derivative Facilities of a Private Company are considered an allowed USR in the ACLDC. Refer to Exhibit C - Land Use, Transportation, and Recreation - Arapahoe County Map for zoning districts within the County.

4.2 Transportation For the purpose of the following discussions, transportation facilities in and around the Project Area include named roads, railroads, and airports. The U.S. Department of Transportation’s Federal Highway Administration regulates vehicle travel on interstates and other U.S. routes and the Colorado DOT regulates vehicle travel on its state highways and roads. Arapahoe County officials regulate vehicle travel on the county roads. In and around the Project Area, many of these county roads are unpaved and do not include markings for lanes and shoulders. In general, these county roads are situated in a north-south, east-west square grid pattern and are spaced approximately one mile apart.

PAGE 55 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

PSCo has prepared a Draft Road Use Agreement (Appendix C) for Arapahoe County as a template for the Final Road Use Agreement, which will identify existing and proposed temporary and permanent access roads. More specifically, the Final Road Use Agreement will identify existing roads to be used in their present condition, existing roads that will require modifications or upgrades to accommodate the Project’s construction vehicles, and proposed access roads in new locations. The Final Road Use Agreement will also describe precautions for ensuring the traveling public’s and construction workers’ safety, including utilizing flagmen and pilot cars to control traffic, and signing alternate travel routes or detours.

4.2.1 Existing Conditions In Arapahoe County, transportation facilities in the Project Area include the Interstate 70 (I-70), U.S. Route 40, and U.S. Route 287 corridor, U.S. Route 36, State Route 40, numerous county roads, the Union Pacific Railroad, and East Moore Field, a private airport. Table 4-1 below lists more information about each facility. Additionally, the Project Area includes unnamed dirt roads that land owners use to access crops and pasture/rangeland. These unnamed roads are not listed in Table 4-1, but may be used for access during the Project’s construction, operation, and maintenance activities with permission from each landowner. As mentioned previously, the Final Road Use Agreement will identify existing and proposed temporary and permanent access roads. Refer to Exhibit C - Land Use, Transportation, and Recreation - Arapahoe County Map for transportation facilities within the County.

Table 4-1 Transportation Facilities In and Around the Project Area – Arapahoe County Number of Transportation Facility General Location Orientation Surface Lanes I-70 U.S. Route 40 Bisects the Town of Deer Trail. North-South 4; 2 NB, 2 SB Paved U.S. Route 287 Parallel to and co-located with the U.S. Route 36 East-West 2; 1 EB, 1 WB Paved Arapahoe-Adams County Line. Generally parallel to I-70 along the State Route 40 North-South 2; 1 NB, 1 SB Paved Town of Deer Trail’s west side. Approximately 4 miles north of the Space for 2 East County Route 18 East-West Dirt / Gravel Town of Deer Trail. lanes of travel East County Route 34 / Extends east from the Town of Deer East-West 2; 1 EB, 1 WB Paved Jolly Road Trail. County Route 38 / Borders the Town of Deer Trail’s Space for 2 East-West Dirt / Gravel Woodis Road southern limit. lanes of travel County Route 47 / Approximately 1 mile south of the Space for 2 East-West Dirt / Gravel Wall Road Town of Deer Trail. lanes of travel County Route 221 / Approximately 1 mile east of the Space for 2 North-South Dirt / Gravel Huntington Road Town of Deer Trail. lanes of travel County Route 229 / Approximately 3 miles east of the Space for 2 South Deter-Winters North-South Dirt / Gravel Town of Deer Trail. lanes of travel Road Approximately 6 miles east of the Space for 2 East County Route 241 North-South Dirt / Gravel Town of Deer Trail. lanes of travel Approximately 6.5 miles southeast Space for 2 East County Route 245 North-South Dirt / Gravel of the Town of Deer Trail. lanes of travel County Route 269 / Approximately 11 miles east of the Space for 2 North-South Dirt / Gravel E Road Town of Deer Trail. lanes of travel

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Number of Transportation Facility General Location Orientation Surface Lanes Approximately 11 miles east of the Space for 2 4 Mile Road North-South Dirt / Gravel Town of Deer Trail. lanes of travel Extends north from the Town of South Price Road North-South 2; 1 NB, 1 SB Paved Deer Trail. Approximately 3 miles northeast of Space for 2 Hampden Avenue East-West Dirt / Gravel the Town of Deer Trail. lanes of travel Approximately 4 miles east of the Space for 2 South Hayward Road North-South Dirt / Gravel Town of Deer Trail. lanes of travel Generally parallels the west side of UP Railroad North-South Not Applicable Railroad Bed State Route 40 Approximately 6.5 miles northwest East Moore Field of the Town of Deer Trail on South North-South Runway 18/36 Dirt Horrogate Road. NB = northbound; SB = southbound; EB = eastbound; WB = westbound

In Arapahoe County, East Moore Field (FAA identifier: 8CO4), a private use airfield, is the closest airport to the Project’s transmission route alternatives. This airport does not have published instrument procedures but is depicted on the Denver Sectional chart. The airport features a 2,600-foot-long, 40-foot- wide dirt runway (AirNav.com 2016).

4.3 Visual Resources and Aesthetics This section describes visual and aesthetic resources in the Project Area for Arapahoe County. Data for the visual resource analysis was drawn from various sources, including the following:

• Arapahoe County Comprehensive Plan and Amendments (Arapahoe County 2001) • Arapahoe County Open Spaces Website • National Land Cover Database (NLCD 2011) • Colorado Parks and Wildlife Website • Google Earth • Site visits by visual resource specialist to the Project Area

4.3.1 Regional Context The regional landscape is characterized by open, expansive high plains and topographically variable, dissected landscape of eastern Colorado. Foothills on the Colorado Front Range transition to flatter, more gently undulating landforms to the east. Ribbons of riparian vegetation within floodplains provide most of the wooded areas adding visual interest by introducing greater vertical variability, additional color and texture into the uniform, low growing homogeneous short-grass prairie vegetation that dominates the regional landscape. This low growing vegetation often appears undeveloped, but grazing and ranching modify the natural landscape by introducing water impoundments, fence lines, corrals, sheds and other associated structures.

Cultivated dryland agriculture is common throughout the region and introduces a more uniform groundcover than the native shortgrass prairie landscapes. Other built landscape features include transportation corridors (roads, highways, and railroads), small and large scale overhead utility corridors, agricultural structures and associated residences, and suburbanized clusters in and around towns and

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incorporated areas. Utility scale wind development also adds a developed character to typically rural settings within the region. The utility corridors, distribution and telephone lines, communication structures, and wind farms also provide additional distinctive, built, vertical developed elements to the horizontally- oriented landscape. Residences typically have a high visual sensitivity. Recreation areas may have a high or moderate sensitivity, depending on associate recreational activities and use levels. Highways, county and local roads typically have a moderate to low sensitivity.

4.3.1.1 Arapahoe County Arapahoe County’s natural features and developed landscapes within the Project Area reflect the broader agriculturally dominated landscapes of the region. Cultivated dryland agriculture and dispersed clusters of agriculturally associated structures and residences define landscape character. The Project Area’s natural landscape is typically characterized by shortgrass prairie and rolling rangeland vegetated with shortgrass prairie grasses and few clusters of trees. The East Bijou Creek riparian corridor is a scenic natural feature within the Project Area. Although it is a perennial stream, flowing water is not visually apparent. The Muddy Creek drainage is also a significant landscape feature, but there is no substantial riparian vegetation associated with the stream and it generally blends with the landscape except in the immediate vicinity of the stream corridor. Existing utility corridors often dominate the viewshed in the Project Area in Arapahoe County. Refer to Exhibit E - Scenic Areas and Visual Quality - Arapahoe County for landscape features and visually sensitive areas. Also see Appendix E for characteristic photos of Arapahoe County’s landscape.

Visually sensitive areas include the Deer Trail area, I-70, County roads, and dispersed residences. Viewsheds are generally open and panoramic, except in areas in and around Bijou Creek where tree cover provides screening, and from within more densely developed area of Deer Trail where landscaping and structures screen and limit the potential viewshed. Localized areas of more variable topography occasionally limit panoramic views, but this is an exception. Key Observation Points (KOPs) showing representative and important viewsheds, scenic vistas, unique landscapes within Arapahoe County are shown in Exhibit F (Photosimulations of Proposed Transmission Line).

4.4 Soils, Geology and Natural Hazards Existing soils data were obtained from the NRCS soil surveys and the Soil Survey Geographic (SSURGO) database for the area. This included the soil surveys and SSURGO data of Arapahoe County (NRCS 1964-2005; NRCS 2016). Soil, geology, and natural hazards information was obtained from the Colorado Geological Survey website and the U.S. Department of Agriculture (USDA) Handbook 296.

4.4.1 Regulations

4.4.1.1 Federal Soil erosion is governed by regulations contained in U.S. Environmental Protection Agency stormwater management regulations (40 Code of Federal Regulations [CFR] §§ 122.26, 123.25), pursuant to Section 402 of the CWA (33 United States Code [U.S.C.] § 1342).

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Under the CWA, the National Pollution Discharge Elimination System (NPDES) stormwater program requires operators of construction sites one acre or larger (including smaller sites that are part of a larger common plan of development) to obtain authorization to discharge stormwater under an NPDES construction stormwater permit. The development and implementation of a SWPPP is the focus of NPDES stormwater permits for regulated construction activities. A SWPPP is required to control discharges for storm events.

4.4.1.2 State Most states, including Colorado, are authorized to implement the stormwater NPDES permitting program. Compliance with state requirements will be necessary for construction stormwater activities. All Colorado stormwater general permits (NPDES #NER11,0000) may be obtained by submitting a Notice of Intent and fee and at the conclusion of construction activities, terminated by submitting a Notice of Termination to the Colorado Department of Public Health and Environment.

4.4.1.3 County The information that will likely be required for the counties includes a Grading, Erosion, and Sediment Control Plan, which would be part of a SWPPP for the Project. A drainage study may be required as well.

PSCo submitted a drainage and stormwater plan (Grading, Erosion, and Sediment Control Study, 2012) for the initial development of the Missile Site Substation, which includes plans and calculations for the total buildout for the substation. The sizing of the existing stormwater pond reflects the total impervious area of structures and equipment pads. PSCo does not anticipate additional development at the Missile Site Substation after the construction of the Project.

4.4.2 Existing Conditions

4.4.2.1 Regional Conditions The Central High Plains Major Land Resource Area (MLRA) is on an elevated, smooth to slightly irregular plain consisting of sediments deposited by rivers that drained the young and actively eroding Rocky Mountains. This old plain is now a dissected peneplain with a few dissected, lava-capped plateaus and buttes. In many areas, the undulating to rolling shale plain is mantled by loess or windblown sand, alluvium, and outwash. East-flowing streams and rivers have slowly been eroding the sedimentary formations, exposing older Cretaceous-aged formations while depositing Quaternary-aged alluvium along eastern terraces and floodplains. The Project Area crosses a highly diverse landscape of exposed Cretaceous-aged formations and Quaternary-aged alluvial and eolian deposits.

The dominant soil orders in this MLRA are Mollisols, Alfisols, Aridisols, and Entisols. The soils in the area dominantly have a mesic soil temperature regime, an aridic or limited soil moisture regime, and mixed, carbonatic, or smectitic mineralogy. They are very shallow to very deep, generally well drained, and loamy or clayey.

Prime farmland, as defined by the USDA, is land that has the best physical and chemical characteristics for production of food, feed, forage, fiber, and oilseed crops and is available for these uses. It could be cultivated land, pasture land, forestland, or other land, but it is not urban or built-up land or water areas.

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Although the NRCS has rated the vast majority of the soils in the area as not prime farmland (NRCS 2016), nearly all of this area is in farms or ranches. About two-thirds of the area supports native short grasses used for grazing. About one-tenth of the area is dry-farmed and winter wheat, corn, and grain are the main crops.

Much of the area is considered low risk for geologic and natural hazards. The topography has fairly level relief (0-10 percent slope), with gently rolling terrain and floodplains occasionally interrupted by drainages with steeper side slopes. The occurrence of major landslides within the area has not been recorded, although the potential for sheet and rill erosion and gully formation may be moderate to severe in some areas. For seismic purposes, Colorado is considered a region of minor earthquake activity, although there are many uncertainties because of the very short time period for which historical data are available. This portion of eastern Colorado and Arapaho County can be considered aseismic.

The Colorado Geological Survey has not identified any points of geological interest in this area (Colorado Geological Survey 2016). Refer to Exhibit G – Soil Qualities - Arapahoe County for soil information.

4.4.2.2 Arapahoe County

Soils The dominant soils in the eastern portion of the county are silt loams, sandy loams, and loams on nearly level to gently sloping uplands with slopes ranging from 0 to 10%. A small percentage of soils are on hills and ridges with slopes ranging from 5 to 20%. There are no all hydric soils in this area and the small number of hydric soil inclusions is less than 0.01% of the area. The hydric soils are located on streams, floodplains, and swales.

Erosion Potential Soils are subject to erosion from wind and water. Wind erodibility indicates the potential for wind erosion based on slope, soil types, and wind characteristics. Wind erodibility is relatively low where slopes are gentle (0 to 14%) and soils are permeable as well as vegetated, which is the majority of the area. Wind erodibility is moderate on steeper slopes (greater than 15%) and on low permeable soils with little to no vegetation. Wind farms are being proposed in this area because of appropriate wind characteristics, so this factor generally increases the overall wind erodibility of the area.

Water erosion is slight to moderate due to the highly permeable nature of soils, except where slopes are steep (over 15 percent). The NRCS rates the erosion hazard for soils for both off-road use and unsurfaced road use. Approximately 15% of the area is rated as severe for erosion hazard for unsurfaced road use which indicates erosion hazard after roads are built. Approximately one percent of the area is rated as severe for erosion hazard for off-road use which indicates erosion hazard after off-road disturbance activities occur (NRCS 2016). These ratings are based on soil erosion factor K, slope, and content of rock fragments. A severe rating indicates that significant erosion is expected, roads or trails require frequent maintenance, and erosion control measures are needed. The remaining soils types are rated as slight to moderate erosion hazard, with approximately three percent of the soils not rated.

Prime Farmland The NRCS identifies approximately 30% of the Project Area as prime farmland, if irrigated or prime farmland, if irrigated with other conditions (NRCS 2016). The prime farmland is located where the slopes

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range from 0 to 9 percent and soils are suitable for farming practices. The main soil types designated as prime farmland include Adena, Colby, Weld, and Deertrail silt loams and fine sandy loams.

4.5 Water Resources and Wetlands Surface water data were obtained from the U.S. Geological Survey National Hydrography Dataset GIS database. Groundwater information was obtained from the Colorado Department of Natural Resources, Division of Water Resources website and the USDA Handbook 296.

Digital wetland inventory maps were obtained from the USFWS NWI. The NWI maps provide approximate locations of wetlands one acre or larger that may or may not be jurisdictional based on the 1987 USACE Wetlands Delineation Manual. In this report, wetlands are classified according to the Cowardin system (Cowardin et al. 1979), which was used by the USFWS to inventory and map the wetlands in the Project Area.

Playa lake information was obtained from the Playa Lakes Joint Venture, which creates and maintains a region-wide spatial data layer of probable playas and county-based maps of probable playa locations. Multiple sources of geographic data went into making the playas data layer and maps, including the NWI, SSURGO database, and satellite imagery (Playa Lakes Joint Venture 2016).

4.5.1 Regulations

4.5.1.1 Federal The CWA (33 U.S.C. §1251 et seq.) was enacted with the intent of restoring and maintaining the chemical, physical and biological integrity of the waters of the U.S. Specific sections of the CWA that may apply to the Project include the following:

• Section 303(d) List of Impaired Waters • Section 130.7 Total Maximum Daily Load • Section 401 Water Quality Certification • Section 402 National Pollutant Discharge Elimination System Permits • Section 404 Waters of the U.S. Permits

4.5.1.2 State The CDPHE, Water Quality Control Division authorizations and guidance that are applicable to wetlands and waters of the U.S. Permitting and mitigation requirements for the Rush Creek Project are summarized below.

• CWA Section 401 Water Quality Certification (WQC). • Under the Colorado 401 Certification Regulation, all Nationwide CWA Section 404 permits are certified by statute and do not require a certification by the Water Quality Control Division. • All WQCs for Individual CWA Section 404 permits and licenses are subject to specified state requirements. For Individual CWA Section 404 permits, documents must be submitted to the Water Quality Control Division for CWA Section 401 certification.

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• In 2012, the CDPHE Water Quality Control Division certified, with conditions, the use of Nationwide Permit 12 in the State of Colorado.

4.5.1.3 County The permits and information that will likely be required for the counties includes the following:

• Surface water impact analysis, • Wetland and riparian impact analysis, • Floodplain Study • A Grading, Erosion and Sediment Control Plan, which would be part of a SWPPP developed for the Project and a drainage study may be required as well.

4.5.2 Existing Conditions

4.5.2.1 Regional Conditions

Climate The Project Area lies in the Central High Plains Major Land Resource Area (MLRA) of the Great Plains Province, a region of elevated piedmont plain that adjoins the Rocky Mountains. Across much of the plains, annual precipitation is less than potential evapotranspiration, resulting in moisture deficits and a semi-arid climate (Bailey 1995).

Surface Water and Groundwater Many rivers, including the South Platte and Arkansas Rivers, flow east across this region from their headwaters in the mountains. Due to limited rainfall, groundwater recharge and discharge occur mainly in depressions, and water tables are usually mounded beneath depressions and drainages. Approximately 29% of water withdrawals are from ground water sources and 71% is from surface water sources. In this region, the surface water is of good quality and has few limitations affecting its use (USDA 2006).

The Denver Basin aquifer underlies an area of approximately 7,000 square miles that extends from Greeley south to near Colorado Springs and from the Front Range east to Limon. This aquifer is not well connected to other major aquifers in the area. The water generally has more than 1,000 parts per million total dissolved solids and is considered soft. The water generally contains sodium bicarbonate and sulfate ions (USDA 2006). The deeper consolidated sand and gravel deposits in the Denver Basin aquifer provide water for livestock, for some domestic use, and for limited local irrigation.

Wetlands Wetlands occupy only a small percent of the semi-arid Central High Plains landscape (Dahl 1990), but their diversity is high, including freshwater marshes, wet meadows, floodplain and riparian wetlands, seeps, fringe wetlands surrounding lakes and reservoirs, playa lakes, and other fresh depressional systems. Wetlands are often discharge systems, and the water table is a muted reflection of surface topography (Richardson et al. 2001).

The predominate NWI identified wetlands in this area are palustrine wetlands including unconsolidated bottom (PUB), unconsolidated shore (PUS), and emergent (PEM). The PUB classification includes all

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wetland and deepwater habitats with at least 25% cover of particles smaller than stones and a vegetative cover less than 30%. The PUB classification includes all wetland habitats having three characteristics: 1) unconsolidated substrates with less than 75% areal cover of stones, boulders, or bedrock; 2) less than 30% areal cover of vegetation other than pioneering plants; and 3) any of the following water regimes: irregularly exposed, regularly flooded, irregularly flooded, seasonally flooded, temporarily flooded, intermittently flooded, saturated, or artificially flooded. PEM wetlands are characterized by perennial, erect, rooted, herbaceous hydrophytes, excluding mosses and lichens. This vegetation is present for most of the growing season in most years.

The PEM, PUB, and PUS wetlands are located adjacent to streams or smaller drainages associated with these streams, as well as in small depressions. The PEM wetlands are dominated by graminoids (sedges, rushes, grasses) and have soils saturated near the surface in early summer, but rarely have standing water and are typically dry by the end of the growing season.

The PUB, PUS, and PEM wetlands are primarily located adjacent to streams or smaller drainages associated with these streams. Some of the PUB and PUS wetlands would be considered playa lakes. Playa lakes are a common wetland type in the region which are shallow circular basins apparently formed by wind erosion and/or calcium carbonate dissolution. Precipitation and local runoff are usually held at the surface by a clay-rich layer, forming shallow ponds and vegetated wetlands. Water is lost through evapotranspiration and seepage at the basin margins above the level of the clay layer. Wetland plants in playas are typically annuals that frequently change during a growing season in response to precipitation. The most commonly encountered plants include: ragweeds (Ambrosia spp.), goosefoots (Chenopodium spp.), kochia (Bassia spp.), spikerushes (Eleocharis spp.), and bulrushes (Schoenoplectus and Scirpus spp.) (Culver and Lemly 2013).

There are a smaller number of riparian wetlands associated with the larger streams in the area. The riparian wetlands consist of palustrine forested (PFO), palustrine scrub-shrub (PSS) wetlands and some PEM wetlands. PFO wetlands are characterized by woody vegetation that is 6 meters (20 feet) tall or taller. PSS wetlands include areas dominated by woody vegetation less than 6 meters tall. In this region, the woody plants include willows (Salix spp.), alders (Alnus spp.), birch (Betula spp.), and cottonwood (Populus spp.) trees. A few intermittent riverine (R4) wetlands are associated with the larger streams in this area as well. In this riverine subsystem, the channel contains nontidal flowing water for only part of the year. When the water is not flowing, it may remain in isolated pools or surface water may be absent.

Floodplains Arapahoe County floodplains were mapped in GIS using Federal Emergency Management Agency (FEMA) and cross-checked with Arapahoe County’s ArapaMap 3.6 online mapping tool (see Exhibit B – Water Resources – Arapahoe County Map). Arapahoe County regulated floodplains (a drainage tributary area of 130 acres or more) were analyzed in GIS and crossings were quantified. A separate Floodplain Study Report was prepared and submitted to Arapahoe County as a separate document with this Application. In Arapahoe County, Alternatives A, B, E, and H do not cross FEMA Floodplains and cross seven (7) Arapahoe County regulated floodplains. Alternatives C, F, and G cross the lowest number of Arapahoe County regulated floodplain crossings (eight crossings) and these Alternatives have the highest total length of FEMA-designated floodplains with 0.8 miles. Alternative D crosses the highest number of Arapahoe County regulated floodplains with 26 crossings. In Arapahoe County no perennial streams, ephemeral streams, or river are crossed. Alternatives C, F, and G have nine intermittent stream

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crossings; Alternatives A, B, E, and H have 15 intermittent stream crossings; and Alternative D has 25 intermittent stream crossings. A summary of wetlands, floodplains, and stream crossings by alternative in Arapahoe County is included in Table 5-3 (Section 5.5.7).

4.5.2.2 Arapahoe County

Surface Water The Project is located in the eastern area of Arapahoe County which is within the Bijou, Beaver, and Middle South Platte – Sterling watersheds (Hydrologic Unit Codes 1019001, 10190013, and 10190012 respectively). There are no rivers in the Project Area, but there are seven named creeks including East Bijou, First, Muddy, Badger, Cottonwood, Rattlesnake, and Beaver. East Bijou Creek and Muddy Creek are the only two streams which have mapped floodplains by the FEMA. Arapahoe County regulatory floodplains (a drainage tributary area of 130 acres or more) were identified and mapped. Noonen Reservoir is the only lake or reservoir in the Project Area and it is located on Muddy Creek on the north side of the county, south of U.S. Highway 36. Refer to Exhibit B – Water Resources – Arapahoe County Map for more information on surface water in Arapahoe County.

In compliance with the CWA, CDPHE has identified 303(d) water quality limited streams and lakes for development of Total Maximum Daily Load criteria. Within the Project Area, the only waterbody listed as impaired or 303(d) listed is Beaver Creek, a tributary of the South Platte River. The Beaver Creek impairments are Escherichia coli (E. coli) and selenium and the cause of these impairments are pathogens and metals (other than mercury) (Environmental Protection Agency 2012).

Groundwater Two smaller aquifer systems occur within the Project Area, the Laramie-Fox Hills aquifer and Laramie Formation aquifer, which are part of the Denver Basin aquifer. The depth of water wells in these aquifers ranges from approximately 25 to 600 feet.

A portion of the Project Area is within the North Kiowa Bijou 7 groundwater management district. There are no designated groundwater recharge areas in the Project Area.

Wetlands A few PUB, PUS, and PEM wetlands are scattered throughout the Project Area, which are relatively small in size. These wetlands are primarily located adjacent to streams or smaller drainages associated with these streams and in small depressions. Some of the PUB and PUS wetlands may be considered playa lakes as described above. There are a few PFO and PSS wetlands adjacent to the East Bijou Creek. A few R4 wetlands are also associated with East Bijou Creek.

4.6 Biological Resources

4.6.1 Introduction This section describes, terrestrial and aquatic plant life, terrestrial and aquatic species, and associated habitat in the Project Area. Data for the Arapahoe County portion of the Project was drawn from various sources, including the following:

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• Colorado Natural Heritage Program (CNHP) • Colorado Department of Agriculture, Colorado Noxious Weeds • Colorado Parks and Wildlife (CPW) Threatened and Endangered List • Colorado Parks and Wildlife National Diversity Information Source • United States Federal Emergency Management Agency, Floodplains • United States Department of Agriculture, Plant Database • United States Fish and Wildlife Service Information, Planning and Conservation System (USFWS IPaC) • United States Fish and Wildlife Service National Wetland Inventory • United States Fish and Wildlife Service Species Report - Arapahoe County • Project field visits by PSCo and POWER staff (May and June 2016).

4.6.1.1 Regulations

Federal The United States’ Endangered Species Act (ESA) protects federally listed plant and animal species with the goal of ensuring their long-term survival. The ESA is administered by the United States Fish and Wildlife Service (USFWS).

The United States’ Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act regulate vegetation clearing, earth-moving, bridge demolition, and other construction activities that have the potential to disrupt nesting activity or destroy nests of bird species protected under the MBTA. The USFWS administers these requirements.

State The Colorado’s Non-game, Endangered, and Threatened Species Conservation Act provides some protection within the State for listed species and establishes the State's intent to protect endangered, threatened, or rare species. The Colorado Parks and Wildlife (CPW) is responsible for listing species.

In addition to regulations primarily designed to protect fish and wildlife species, regulations are in place to protect habitat from plant species determined to be “noxious. The Colorado Department of Agriculture Noxious Weed Act of 2003 (Colorado Revised Statutes [CRS] 35-5-101; CRS 35-5.5-101; Executive Order D-006-99), defines and prioritizes management objectives for State-designated noxious weeds.

Colorado Senate Bill 40 (SB 40) requires that State agencies obtain certification from CPW when an agency plans construction in any stream, stream bank, or tributary. Any portions of the Project that could impact an SB 40 Jurisdictional stream may require SB 40 certification, which would include mitigation measures designed to improve fish and wildlife habitat.

4.6.2 Existing Conditions The Project is located within the High Plains and Southwestern Tablelands ecoregions of Colorado (Chapman et al. 2006). There are several regions within each ecoregion. The Project Area south/southeast of Limon, Colorado is within the Moderate Relief Plains and Flat Rolling Plains regions of the High Plans ecoregion. The regions are typified by irregular plains and the land use is predominantly rangeland and dryland farming Winter wheat is the main cash crop, with a smaller acreage in forage

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crops. Soils are silty and clayey loams, formed from eolian sediments and with veneer loess as you head to the uplands. Blue grama-buffalograss was the natural prairie type. Land is mostly rangeland and irrigated agriculture occurs along the Big Sandy Creek.

The Project Area west and northwest of Limon, Colorado is within the Piedmont Plains and Tablelands region of the Southwestern Tablelands ecoregion. This vast region consists of irregular and dissected plains underlain by shale and sandstone. The shortgrass prairie within this region contains buffalograss (Bouteloua dactyloides), blue grama (Bouteloua gracilis), western wheatgrass (Pascopyrum smithii), galleta (Pleuraphis jamesii), alkali sacaton (Sporobolus airoides), sand dropseed (Sporobolus cryptandrus), sideoats grama (Bouteloua curtipendula), and yucca (Yucca spp. L.).

4.6.2.1 Terrestrial and Aquatic Wildlife

Wildlife and Wildlife Habitat Existing land uses along the Project Area in Arapahoe County consists primarily private land dryland agriculture and pasture/grazing (rangeland). An existing transmission line utility corridor, the Missile Site to Limon 230 kV Transmission Line, is paralleled along the entire Preferred Route (Alternative A) in Arapahoe County. Given the presence of the agricultural lands, rangeland and existing utility corridor, it is likely that the natural vegetation, soils, and hydrology have been altered by these activities.

The Project Area is within the Western Great Plains Shortgrass Prairie (CNHP 2016). In much of its range, this system forms the matrix system with Bouteloua spp. dominating. Other associated graminoids may include Buchloe dactyloides, Hesperostipa comata, Koeleria macrantha (= Koeleria cristata), Pascopyrum smithii (= Agropyron smithii), Aristida purpurea and Sporobolus cryptandrus. Although tallgrass and mixed grass species may be present especially on more mesic soils, they are secondary in importance to the sod-forming short grasses. Shrub species such as sand sagebrush (Artemisia filifolia), big sagebrush (Artemisia tridentata), and rabbitbrush (Chrysothamnus spp.) that dominate the Western Great Plains shrubland systems may also be present. A healthy shortgrass prairie system should support prairie dog (Genus Cynomys) complexes, viable populations of pronghorn, endemic grassland birds, and other Great Plains mammals such as swift fox (Vulpes velox), white-tailed deer (O. virginianus), mule deer (Genus Odocoileus), pronghorn (Antilocapra americana), and coyote (Canis latrans) (CNHP 2005). However, the shortgrass prairie landscape within the Project Area is almost entirely dominated by lands converted to agriculture, rangeland and urban uses. Refer to Exhibit H – Terrestrial and Aquatic Animal and Plant Habitat – Arapahoe County Map for more information. Section 5.6 addresses impacts to Biological Resources. Section 5.6.1, Impacts to the Preferred Alternatives, discusses mitigation. Section 5.6 also discusses BMPs and other pre-emptive activities to reduce impacts and mitigation measure to protect Biological Resources.

General Wildlife and Livestock Animal husbandry and livestock production has altered the look and character of the shortgrass prairie (CPW 2003). This alteration and fragmentation has changed the level of wildlife diversity once supported by the landscape. Species that regularly occur in the Project Area include American badger (Taxidea taxus), mule deer, pronghorn, white-tailed deer, coyote, prairie rattlesnake (Crotalus viridis), swift fox, prairie dog and other common species. Most grassland reptiles are widely distributed.

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Raptors and Other Migratory Birds Numerous avian species may be present within the Project Area in Arapahoe County. These include year-round residents or migrant species passing through the Project Area during the spring/fall or use the area for nesting during the spring/summer or overwinter. The Project Area is within the Central Flyway and the majority of the birds that use it make direct north and south journeys from breeding grounds in the North to winter quarters in the South. Resident avian species utilizing the grassland structures ranging from heavily grazed and even bare areas to dense and tall cover includes species of grassland birds, waterfowl and raptors. Common representative species of waterfowl found within the Central Flyway in Colorado includes the common mallard (Anas platyrhynchos), American widgeon (Anas americana), shoveler (Anas clypeata), northern pintail (Anas acuta), goldeneye (Bucephala clangula), redhead (Aythya americana), merganser (Mergus merganser), snow goose (Chen caerulescens), and American coots (Fulica americana) (USFWS 2016). Representative raptors species include red-tailed hawk (Buteo jamaicensis), Swainson’s hawk (Buteo swainsoni), prairie falcon (Falco mexicanus), northern harrier (Circus cyaneus), American kestrel (Falco sparverius), golden eagle (Aquila chrysaetos canadensis), rough-legged hawk (Buteo lagopus) and great horned owl (Bubo virginianus). Representative grassland species include horned lark (Eremophila alpestris), Western meadowlark (Sturnella neglecta), lark sparrow (Chondestes grammacus), mourning dove (Zenaida macroura), and American goldfinch (Spinus tristis).

Information regarding raptor nest occurrences was obtained from the CPW, CNHP and survey reports from projects within the Project Area. No active raptor nests were identified within the Project Area in Arapahoe County (CPW 2016a; SWCA 2016; CNHP 2016; CPW 2008).

Aquatic Wildlife No perennial streams or other suitable aquatic habitat to support fisheries populations, fisheries of special concern, or essential fish habitat were identified within or immediately adjacent to the Project Area within Arapahoe County. Most grassland amphibians are widely distributed. The number of species in any location is a function of the presence of water (which amphibians need to complete their life cycle) and of complex habitats (CPW 2003).

Federal and State Listed Species Lists of federally listed threatened, endangered, proposed, and candidate species with the potential to occur were obtained by county using the USFWS IPaC system (USFWS 2016). Information regarding the potential occurrence of state-listed species of concern (including state endangered, threatened, special concern, species deemed in need of management, and historic species) was obtained from the CNHP and from the CPW (CNHP 2016; CPW 2016a, b, c, d, e). Additional information was obtained from the National Diversity Information Database (NDIS), USDA plant database and survey reports in the Project area (NDIS 2016, USDA 2016). Data from the agencies included site-specific species occurrence data for the Project Area and a five-mile area buffer to account for potential movement by species into the Project Area. For the purpose of this study, this information is not used as a substitute for a presence/absence survey, but as an indication of previous occurrences within suitable habitat for the species.

The USFWS regulates activities affecting plants and animals designated as endangered or threatened under the ESA (16 U.S.C. § 1531 et seq.). By definition, an endangered species is in danger of extinction throughout all or a significant portion of its range. A threatened species is defined as likely to become endangered within the near foreseeable future throughout all or a significant portion of its range.

PAGE 67 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Candidate species are those that have sufficient information on their biological vulnerability and threat(s) to support listing as threatened or endangered and might be proposed for listing in the near foreseeable future. The ESA also provides for the conservation of “designated critical habitat,” which is defined by the USFWS as the areas of land, water, and air space that an endangered species needs for survival. Designated critical habitat includes sites with food and water, breeding areas, cover or shelter sites, and sufficient habitat to provide for normal population growth and behavior for the species. USFWS data regarding designated critical habitat areas were reviewed (USFWS 2016a). No designated critical habitat areas were identified within the Project Area.

Table 4-2 lists the federally and state-listed wildlife species with potential to occur in Arapahoe County and indicates whether potential habitat for each species occurs within the Project Area.

4.6.2.2 Terrestrial and Aquatic Plant Life

Vegetation Communities

Cropland/Rangeland This community consists of irrigated cropland in limited areas, with cultivated dryland agriculture being most prevalent. The majority of the Project Area appears to be used for hay production or as pastureland with grazing of domestic livestock. This vegetation community is largely disturbed.

Barren Land (Rock/Sand/Clay) This community consists of bedrock, desert pavement, scarps, talus, slides, gravel pits and other accumulations of earthen material. Generally this vegetation community accounts for less than 15 percent of total cover.

Developed Developed areas include roads, built structures, and associated infrastructure. Areas generally considered developed include dirt and paved roads, transmission lines, railroads, and any other permanent structures. Ornamental landscaping is associated with developed areas, and can consist of both maintained native and non-native plant species.

Western Great Plains Shortgrass Prairie In much of its range, this system forms the matrix system with grama grass (Bouteloua spp.) dominating. Other associated graminoids may include buffalograss (Buchloe dactyloides), needle-and-thread grass (Hesperostipa comata), prairie Junegrass (Koeleria macrantha (= Koeleria cristata)), western wheatgrass (Pascopyrum smithii (= Agropyron smithii)), fringed sage (Aristida purpurea) and sand dropseed (Sporobolus cryptandrus). Although tallgrass and mixedgrass species may be present especially on more mesic soils, they are secondary in importance to the sod-forming short grasses. Shrub species such as sagebrush and rabbitbrush that dominate the Western Great Plains shrubland systems may also be present (CNHP 2016). The plains of Colorado are in the shortgrass zone, but fingers of mid-grass prairie extend into the short-grass prairie, and patches of tall grasses occur in riparian areas where conditions are sufficiently moist year-round.

The short grasses that dominate this system are extremely drought- and grazing-tolerant. These species evolved with drought and large herbivores and, because of their stature, are relatively resistant to

PAGE 68 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03 overgrazing. Land use within this vegetation community is primarily rangeland with grazing of domestic livestock.

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Table 4-2 Federally and State-Listed Wildlife Species with Potential to Occur within the Arapahoe County Portion of the Project COMMON SCIENTIFIC LISTING STATUS POTENTIALLY SUITABLE CLASS HABITAT DESCRIPTION NAME NAME FEDERAL 1 STATE 2 HABITAT OBSERVED Nests in summer along reservoirs, lakes and rivers with bare sandy shorelines or islands. In Colorado, least terns breed only Least Tern Sternula E E in the Lower Arkansas River Basin. During migration, they No, lack of suitable habitat. interior population ( ) antillarum occasionally occur in the Lower South Platte River Basin, and less frequently on the west slope (CPW 2016b). Mature, old-growth forests that possess complex structural components; canyons, riparian, and conifer communities. Mixed-conifer forests are commonly used throughout most of Strix the range which may include Douglas-fir and/or white fir, with Mexican occidentalis T T codominant species including southwestern white pine, limber No, lack of suitable habitat. Spotted Owl lucida pine, and ponderosa pine. The understory often contains the above coniferous species as well as broadleaved species such as Gambel oak, maples, box elder, and/or New Mexico locust (USFWS 2016c). Wetlands, lakeshores, and marshes. Nesting habitat is along Birds reservoirs, lakes, and rivers with bare sandy/pebbly areas with Charadrius sparse vegetation. They occur in eastern Colorado as very rare Piping Plover T T No, lack of suitable habitat. melodus migrants and have been known to nest at a few reservoirs: Adobe Creek, John Martin, Neegronda, and Neeskah (CPW 2016c). No. It is rare for whooping cranes to stop in Colorado as Whooping Utilizes wetlands, irrigated meadows, and reservoir edges as Grus americana E E they migrate from central Crane stopovers during migration. Canada to Texas Gulf Coast each fall (CPW 2004) Inhabit treeless areas with short vegetation (<10 cm; 4 in), especially in association with colonies of prairie dogs or ground Athene squirrels. Burrowing owls nest in burrows dug by the rodents, Yes. Known records in the Burrowing Owl n/a T cunicularia and prefer the extremely short vegetation found in the colonies. Project Area. Burrowing owls breed throughout the eastern plains and in river valleys (Rocky Mountain Bird Observatory [RMBO] 2000a).

PAGE 70 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

COMMON SCIENTIFIC LISTING STATUS POTENTIALLY SUITABLE CLASS HABITAT DESCRIPTION NAME NAME FEDERAL 1 STATE 2 HABITAT OBSERVED Prefers subclimax brush-grasslands. The plains sharp-tailed grouse use rolling hills with scrub oak thickets and grassy Tympanuchus Plains Sharp- glades. As an equivalent to sagebrush, they use scrub oaks, No, no records or known to phasianellus n/a E Tailed Grouse serviceberries and willows. In Colorado, birds of the subspecies occur in Arapahoe County. jamesii jamesii reside in Douglas County, northern Weld County, and Logan County (RMBO 2000b). Peregrine falcons breed throughout the Colorado Plateau and American Falco Southern Rocky Mountain ecological provinces of Colorado. Peregrine peregrinus n/a C No, suitable habitat However, nesting does not occur on the eastern plains (CPW Falcon anatum 2004). Yes. Could occur during Habitat includes reservoirs and rivers. In winter, they may also migration or winter roosting, Haliaeetus Bald Eagle n/a T occur locally in semi-deserts and grasslands, especially near although unlikely due to the leucocephalus prairie dog towns. lack of large trees in the Arapahoe County Project Area. Preferred habitat is arid and semiarid grassland, foothills or Ferruginous Buteo regalis n/a C mid-elevation plateaus with few trees. Avoids cultivated fields Yes, suitable habitat Hawk and developed areas. In Colorado, greater sandhill cranes select sites that are almost always closely associated with water. The species utilizes large wetlands, irrigated meadows, reservoirs, and river sandbars during the migration through the plains states. Willow-lined streams or beaver ponds are preferred sites in Colorado. At Grus No, lack of suitable habitat and Greater higher elevations, the species prefer open parkland was canadensis n/a C no known nesting sites or Sandhill Crane surrounded by quaking aspen mixed with lodgepole pine (P. tabida records in Arapahoe County. contorta), fir (Abies sp.), and blue spruce (P. pungens) (Stone 2009). In Colorado, a greater sandhill crane migration stopover site is centered on the Monte Vista National Wildlife Refuge, a large complex of marsh habitat surrounded by many small grain fields (Van Graham 2014). Grassland species, but they are rarely observed far from water. In Colorado, they are usually associated with ponds, reservoirs, Long-Billed Numenius n/a C playas, and wet meadows. During migration, long-billed curlews Yes, potential habitat Curlew americanus occur sporadically in western Colorado and regularly throughout eastern Colorado (CPW 2016d).

PAGE 71 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

COMMON SCIENTIFIC LISTING STATUS POTENTIALLY SUITABLE CLASS HABITAT DESCRIPTION NAME NAME FEDERAL 1 STATE 2 HABITAT OBSERVED Snowy plovers nest on sandy beaches or alkaline flats with little or no vegetation; nests are located within 150 m (500 ft.) of Western Charadrius n/a C water. Within the Central Shortgrass Prairie in Colorado, they No, lack of suitable habitat. Snowy Plover alexandrinus breed on the shores of reservoirs near the Arkansas River between La Junta and Lamar (RMBO 2000c). Habitat includes prairie grasslands, arid plains, and fields. Mountain Charadrius Yes. Record of species in the n/a C Nesting occurs on grazed shortgrass prairies, overgrazed Plover montanus area tallgrass prairies, and fallow fields. The species requires turbid water, diverse habitat types, and Scaphirhynchus flow rates afforded by large, free flowing rivers (USFWS 1993).

Fish Pallid Sturgeon E Scaphirhynchusn/a albus No, lack of suitable habitat albus Known population in Mississippi River from Missouri to the Gulf of Mexico. Preble’s Zapus Occurs in the Front Range along permanent or intermittent Meadow hudsonius T T streams in areas with herbaceous cover and adequate cover of No, lack of suitable habitat. Jumping preblei shrubs and trees. Mouse Habitat consists of intermixed shrublands, sagebrush habitat, Black-Tailed Cynomys Yes, species known to occur in n/a C and/or shortgrass and mixed-grass prairies. Occurs in central Prairie Dog ludovicianus Project area. and south-central Colorado. No. Population has been Black-Footed Occurs in grasslands or shrublands in association with prairie extirpated in Colorado, with the Mustela nigripes E E Ferret dog colonies. exception of managed Mammals experimental populations. Northern Thomomys The northern pocket gopher occurs in upland areas of the n/a C Yes. Suitable habitat present. Pocket Gopher talpoides eastern plains (Colorado State University 2016). Yes. Suitable habitat is present Swift fox typically prefer short- or mixed-grass prairie with flat and has been observed within to gently rolling terrain and low-growing sparse vegetation that the Project Area as recent as allows for good mobility and visibility. The swift fox is native to Swift Fox Vulpes velox n/a C June 2016 during the Great Plains region of North America. Today the swift fox reconnaissance level site visits can be found in fragmented, smaller populations in portions of to the Project Area in Colorado (CPW 2013). Arapahoe County.

PAGE 72 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

COMMON SCIENTIFIC LISTING STATUS POTENTIALLY SUITABLE CLASS HABITAT DESCRIPTION NAME NAME FEDERAL 1 STATE 2 HABITAT OBSERVED A variety of aquatic habitats that include slow-moving or still water along streams and rivers, wetlands, permanent or Northern temporary pools, beaver ponds, and human-constructed Amphibians Rana pipiens n/a C No, lack of suitable habitat Leopard Frog habitats such as earthen stock tanks and borrow pits. Northern leopard frogs have also gone extinct or become severely reduced at low elevation sites in Colorado (CPW 2016e). Inhabits marshes, ponds, and the edges of streams and for the Common Thamnophis Yes, very little suitable habitat n/a C most part restricted to aquatic, wetland, and riparian habitats Garter Snake sirtails exists within the project area. along the floodplains of streams. Reptiles In Colorado, massasaugas are associated with xeric Sistrurus Massasauga n/a C grasslands in the southeastern portion of the state (USFWS No, lack of suitable habitat. catenatus and CPW 2007). Ute Ladies'- Spiranthes Sub-irrigated alluvial soils along streams; open meadows on T n/a No, lack of suitable habitat Tresses diluvialis floodplains, including riparian areas. Plants Western Platanthera Prairie Fringed T n/a Mesic to wet unplowed tallgrass prairies and meadows. No, lack of suitable habitat praeclara Orchid

1 Federal status codes: LE = Endangered PE = Proposed Endangered PT = Proposed Threatened D3C = Delisted taxon, recovered C = Candidate n/a = Not applicable 2 State status codes: E = Endangered T = Threatened S = Special concern D = Deemed in need of management n/a = Not applicable HIGHLIGHTED species are known to occur and/or likely to occur in the Project Area.

PAGE 73 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Eastern Plains Shrubland This system is characterized by a sparse to moderately dense woody layer dominated by sand sagebrush. These shrubs usually do not grow as clumps but as individuals, and the intervening ground is most often dominated by a sparse to moderately dense layer of tall, mid- or short grasses (CNHP 2016). Associated species can vary with geography, precipitation, disturbance and soil texture. Graminoid species such as sand bluestem (Andropogon hallii), sand dropseed (Sporobolus cryptandrus), prairie sandreed (Calamovilfa longifolia), giant sandreed (Calamovilfa gigantea), needle and thread (Hesperostipa comata), and needle grama (Bouteloua spp.) are often associated with this system. Other shrub species may also be present including soapweed yucca (Yucca glauca), honey mesquite (Prosopis glandulosa), skunkbush sumac (Rhus trilobata), and Watson’s plum (Prunus angustifolia).

In eastern Colorado, this system is found primarily in extensive tracts on Quaternary eolian deposits. There are patches of this community along Cottonwood Creek and Badger Creek in Arapahoe County. Land use within this vegetation community is primarily rangeland with grazing of domestic livestock.

Wetlands/Open Water This system includes a variety of depressional wetlands or playas scattered throughout the eastern plains of Colorado and adjacent areas of the Shortgrass Prairie ecoregion. Occurrences are primarily upland depressional basins supporting freshwater wetland vegetation. These wetlands are small, shallow, and generally isolated in an extremely localized watershed, although they are typically part of a larger complex of depressional wetlands embedded in a terrestrial matrix system (CNHP 2016). The basins are typified by the presence of an impermeable layer such as dense clay, and hydric soils. They are rarely linked to outside groundwater sources, and are instead dependent on rainwater and nearby runoff. Ponds and lakes (i.e. open water) associated with this system can experience periodic drawdowns during drier seasons and years, and are often replenished by spring rains.

Please refer to Section 4.5 for additional details regarding surface water and wetland resources within the Project area.

4.6.2.3 Noxious Weeds Noxious weeds are non-native plants and are considered invasive and often crowd out native vegetation, crops or other desirable vegetation. The State of Colorado considers 71 plant species noxious, and Arapahoe County is home to 17 species on this list. The state list is prioritized into three categories: A, B and C. Weeds that are considered List A are rare and have not established in Colorado or occur in limited areas. List B weeds are well established in defined areas throughout the state. List C weeds are widespread and well established, they are considered naturalized. The Colorado Department of Agriculture works with each county to maintain the weed program and develop specific lists of noxious weeds targeted for management (Colorado Department of Agriculture 2013). Ongoing coordination with the State Weed Coordinator is occurring to develop a specific list for the Project Area.

4.6.2.4 Federally Listed Plant Species Two federally-listed plant species have the potential to occur within Arapahoe County, the Ute ladies'- tresses (Spiranthes diluvialis) and Western prairie fringed orchid (Platanthera praeclara). Refer to Table 4-2 for details on the species habitat and potential for occurrence.

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4.7 Paleontological and Cultural Resources

4.7.1 Existing Conditions On behalf of PSCo, POWER Engineers conducted a formal file search request on April 22, 2016, of the Colorado Office of Archaeology and Historic Preservation cultural resource database. In Arapahoe County, the Project centerline alternatives cross one site, which is the only one within 1,000 feet of the Project centerline. Tables 4-3 and 4-4 summarize these results.

Table 4-3 Previously Identified Cultural Resources Crossed by the Project Centerline – Arapahoe County Site Num. Age Site Name NRHP Status 5AH.808 Historic 1869 Union Pacific Railroad Eligible

Table 4-4 Previously Identified Cultural Resources within 1,000 feet of the Project Centerline – Arapahoe County Site Num. Age Site Name NRHP Status 5AH.808 Historic 1869 Union Pacific Railroad Eligible

Site 5AH.808 is the historic route of the Union Pacific Railroad through Arapahoe County (see Appendix H). This resource is considered Eligible for the National Register of Historic Places (NRHP). It is the only cultural resource located along the Preferred Route and the Alternatives in Arapahoe County. This is likely due to the relatively small number of cultural resource inventories that have been undertaken in this portion of the State.

4.8 Socioeconomics Socioeconomics examines how social and economic variables interact to influence population patterns, which in turn can influence the land cover and use patterns described above. Identifying spatial and temporal boundaries helps to understand how social and economic variables interact. Spatial boundaries identify a given geography or place. Temporal boundaries identify a period of time. Unlike the transmission route alternatives’ finite geographic boundaries, the Project’s socioeconomic spatial boundary spans greater distances to include communities that might provide a labor force for Project construction, operation, and maintenance activities and would be expected to provide goods, services, and housing for the Project’s temporary and permanent labor force. The Project’s socioeconomic temporal boundary would be expected to last throughout Project construction, operation, and maintenance activities; essentially lasting for the life of the Project.

In analyzing the Project’s spatial and temporal boundaries, PSCo can estimate where, when, and to what extent the Project would affect socioeconomic variables, which are described below to include population, employment and income, and housing characteristics. For these variables, State of Colorado and county data are presented for comparison to the communities below.

Data presented below were excerpted from the United States Census Bureau (USCB) and the Colorado Department of Labor and Employment’s Labor Market Information Gateway.

PAGE 75 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

4.8.1 Existing Conditions In Arapahoe County, the Project’s socioeconomic spatial boundary includes the City of Aurora, the Census-Designated Place (CDP) of Byers, the Town of Deer Trail, and the CDP of Strasburg. It is important to note that Aurora lies in Adams, Arapahoe, and Douglas Counties, while Byers and Deer Trail lie wholly in Arapahoe County. Strasburg lies in Adams and Arapahoe Counties. Socioeconomic spatial boundaries often cross county and other municipal borders due to favorable real estate prices and tax liabilities, and/or proximity to more goods, services, and housing.

In Arapahoe County, Deer Trail is the closest incorporated town to the transmission route alternatives. Byers and Strasburg lie approximately 11 miles and 17 miles northwest of Deer Trail, respectively. The City of Aurora lies approximately 44 miles west of Deer Trail. Byers, Deer Trail, and Strasburg are small communities compared to Aurora, but are closer to the transmission route alternatives than Aurora and would likely provide adequate goods, services, and housing for the Project’s labor force. Given the uncertainty of where the Project’s temporary laborers may reside, socioeconomic data for all of these communities are presented below.

4.8.1.1 Population According to the USCB, between 2010 and 2014, the populations for Byers, Deer Trail, and Strasburg experienced increases of approximately 3.3% and 5.8%, respectively, while Strasburg’s population increased by approximately 43.6%. Between 2010 and 2015, Aurora’s and Arapahoe County’s population each increased by 10 to 11%, and the State of Colorado’s population increased by approximately 8.5%. Table 4-5 presents these communities’ most recent population estimates.

The Coty of Aurora’s approximate 2,100 people per square mile (mi2) contrasts relatively to Arapahoe County’s approximate 717 people per square mile, Deer Trail’s approximate 351 people per square mile, Byers’ approximate 318 people per square mile, and Strasburg’s approximate 144 people per square mile. The State of Colorado’s population density is far less at approximately 49 people per square mile (USCB 2015).

Table 4-5 Arapahoe County Population Data ARAPAHOE STATE OF AURORA BYERS DEER TRAIL STRASBURG COUNTY COLORADO 359,407a 1,361b 386b 2,999b 631,096a 5,456,574a Source: USCB 2014 and 2015. a 2015 Census estimate. b 2014 Census estimate.

4.8.1.2 Employment and Income From 2010 to 2014, the percentages of the populations age 16 or older who were employed in the civilian labor force in Aurora, Byers, Deer Trail, and Strasburg totaled 70.8%, 62.0%, 53.2%, and 72.0%, respectively. This sector of Arapahoe County’s labor force totaled 71.1%, while the State of Colorado totaled 67.9%. The sector is defined as the population aged 16 or older employed in the civilian labor force. In these geographies, unemployment rates were the lowest in Deer Trail at 1.3% and greatest in Strasburg at 12.9%. Byers’, Arapahoe County’s, and the State of Colorado’s unemployment rates ranged from 7.4% to 8.1%. Aurora’s unemployment rate totaled 10.1% (USCB 2014).

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According to economic characteristics compiled for the USCB’s 2010-2014 American Community Survey, the educational, health care, and social assistance services industry employed the single-largest percentage of workers in Aurora, Byers, Deer Trail, Strasburg, Arapahoe County, and the State of Colorado. In each of these geographies, this industry’s workers accounted for approximately 19 to 27% of the civilian labor force. Professional, scientific, and management services and the retail trade industries’ workers accounted for 10 to 20% of these geographies’ civilian labor force. Other industries’ workers accounted for smaller percentages (USCB 2014).

Table 4-6 presents the median household incomes and per capita incomes for the communities, Arapahoe County, and the State of Colorado. Across these geographies, median household incomes vary by approximately 230% and per capita incomes vary by approximately 72%. The values presented in Table 4-6 reflect 2014 inflation-adjusted dollars (USCB 2014).

Table 4-6 2014 Median Household Incomes and Per Capita Incomes – Arapahoe County ARAPAHOE STATE OF VARIABLE AURORA BYERS DEER TRAIL STRASBURG COUNTY COLORADO Median Household $52,275 $57,721 $32,083 $74,018 $62,213 $59,448 Income Per Capita $24,732 $27,490 $19,511 $25,443 $33,574 $31,674 Income Source: USCB 2014

4.8.1.3 Housing Single-family, detached housing units dominate the housing by type in Aurora, Byers, Deer Trail, and Strasburg, though at greater densities than outlying portions of Arapahoe County. Table 4-7 presents the total number of housing units in these geographies along with the percentage of single-family, detached housing units in these geographies.

Table 4-7 Total Housing Units and Percentage of Single-family, Detached Housing Units – Arapahoe County ARAPAHOE STATE OF VARIABLE AURORA BYERS DEER TRAIL STRASBURG COUNTY COLORADO Total Housing Units 130,835 564 228 1,004 240,486 2,238,624 (Number) Single-Family, Detached 51.0 73.9 59.6 80.2 56.2 62.9 Housing Units (Percent) Source: USCB 2014.

The percentage of vacant housing (single family and multi-family) units is the lowest in Strasburg at 1.5% and greatest in Deer Trail at 21.9%. Aurora’s, Byers’, Arapahoe County’s, and the state’s stock of vacant housing units represents 5.7%, 8.9%, 5.1%, and 10.7% of these geographies’ total housing units, respectively. According to the USCB’s data, there are 7,491 vacant housing units in Aurora, 50 vacant housing units in Byers, 50 vacant units in Deer Trail, and 15 vacant units in Strasburg (USCB 2014).

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5. ENVIRONMENTAL IMPACTS, MITIGATION, AND BEST MANAGEMENT PRACTICES

PSCo analyzed eight end-to-end route alternatives (Alternatives A – H) and selected a Preferred Alternative for the entire Rush Creek 345 kV Transmission Line Project. In Arapahoe County the eight end-to-end route alternatives represent three discrete routes due to several of the end-to-end route alternatives sharing common segments in Arapahoe County. For clarity and comparison of Alternatives, the discussion of the eight end-to-end alternatives that share common route segments have been combined into the following: 1) Alternatives A, B, E and H; 2) Alternatives C, F, and G; and 3) Alternative D. The combined alternative discussions are presented below for each resource.

When considering landowner interest, both within Arapahoe County and along the entire transmission line route, the selected Preferred Alternative was designed to balance minimizing the number of residences passed along the route within Arapahoe County, minimizing the distance passed through sensitive environmental areas, and minimizing impacts to various resources while maximizing engineering design optimization and the purpose and need of the Project. Alternative A was selected as the Preferred Alternative. Alternative A would be the longest alternative through Arapahoe County; however, it would minimize impacts to several key resources and would parallel the existing NextEra 345 kV Transmission Line for its entire length in Arapahoe County. The Preferred Alternative would pass by the fewest number of residences within 1,000 feet and crosses the fewest number of wetlands and floodplains. The Preferred Alternative would rank second for the number of stream crossings and the number of miles through Arapahoe County Sensitive Development Areas; three miles of the preliminary selected route in Arapahoe County were relocated to the west to avoid riparian habitat areas associated with the Muddy Creek drainage. The Preferred Alternative would pass through the most miles of potential prime farmland; however, soils comprising these lands are considered only potential prime farmland and are classified as prime if they are irrigated. The Preferred Alternative would rank second for miles passing through agricultural cropland lands and shortgrass prairie.

5.1 Land Use and Recreation

5.1.1 Impacts and Mitigation

5.1.1.1 Alternatives A (Preferred Alternative), B, E and H Land use impacts are identical for Alternatives A, B, E, and H because they share the same alignment within Arapahoe County. Impacts would result primarily from the footprint area of the 345 kV H-frame transmission line structures removing small areas of dryland agriculture or pasture from production, affecting both private land production and State land leases on the northern portion of the Alternatives. Additionally, improved existing roads or new access roads may minimally affect the area available for grazing; no new permanent access roads are proposed in cultivated cropland. Grazing and pasture impacts would occur on the southern portions of the Alternative within the County. Overland access will be used to the extent possible, but road grading may occur in areas where overland access is not possible. The Preferred Alternative will parallel the existing NextEra 345kV transmission line project, thus reducing resource impacts compared to a greenfield alternative which would have higher resource impacts.

PAGE 79 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Agricultural activities would continue to occur unaffected along the vast majority of land within the 150- foot ROW. Planting and harvesting patterns may need to be adjusted in areas of dryland production to account for structures. Because these Alternatives follow an existing transmission line along the entire length of Alternatives A, B, E and H in Arapahoe County (see Table 5-1) where agricultural land uses occur, operators currently adjust their planting and harvesting patterns to account for existing (H-frame) structures located in agricultural fields. Grazing would continue around the transmission line structures. Existing transmission lines and pipelines would be crossed by these Alternatives (in the same locations) that would require coordination with the respective utility or owning entity (e.g., Tri State Electric, Colorado Interstate Gas Co.). Table 5-1 summarizes land use impacts for Alternatives located in Arapahoe County.

Direct impacts on residential, commercial, institutional, and other land uses would not occur as a result of Alternatives A, B, E, and H. Residential and other structures occur within 0.5 mile of the Alternatives as detailed in Table 5-1, but would not be directly impacted by the Project (please refer to Section 5.3 for Visual Impacts).

No direct or indirect land use impacts on State, County, or local parks, trails, or fishing stream segments would occur as a result of these Alternatives, and there are no parks and recreational areas within 1,000- feet of these Alternatives.

These Alternatives would be consistent with the Arapahoe County Comprehensive Plan because the Project will be evaluated by the County under Use by Special Review/1041 Regulations, and the transmission line will not be constructed in riparian or Sensitive Development Area identified under the Plan. Mitigation measures will be implemented as discussed at the end of this section to reduce impacts on property owners and residents of the County.

5.1.1.2 Alternatives C, F and G For Arapahoe County land use impacts on cultivated and grazing areas would be similar for Alternatives C, F, and G as they are for Alternatives A, B, E, and H, but would occur in a greenfield corridor within the western part of the study area. Cultivated area impacts would occur where the Alternatives cross cropland on the northern portion of the route and in the area east of Deer Trail. Although the total length of the ROW through cropland would be less than Alternatives C, F and G, these Alternatives do not parallel existing transmission lines except along a 2.2-mile section immediately south of the Missile Site Substation. Cultivation currently occurs along the existing lines in this area of Arapahoe County. In the area east of Deer Trail, the Project would create a new transmission line corridor through cultivated areas where none currently exist, causing new impacts as a result of modified planting and harvesting patterns and reduced production potential in areas occupied by the structures. Cultivated area impacts would occur along a higher proportion of Alternatives A, B, E, and H compared to Alternatives C, F, and G. Impacts on grazing would be similar to Alternatives A, B, E, and H. No State land leased for agricultural activities would be impacted by these Alternatives.

Although no residential areas are crossed, the total number of residences located within 0.5 mile and the total number of structures within 0.5 mile of Alternatives C, F, and G would be higher than Alternatives A, B, E, and H (refer to Section 5.3 for Visual Impacts). Impacts on recreation would be identical to Alternatives A, B, E, and H (none).

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Consistency with the Arapahoe County Comprehensive Plan would be identical to Alternatives A, B, E, and H.

5.1.1.3 Alternative D Land use impacts on cultivated areas and rangeland for Alternative D would be similar to Alternatives A, B, E and H in that they would occur adjacent to existing transmission line corridors, but these impacts would occur over greater distance for this Alternative. This Alternative also crosses a higher proportion of rangeland for the entire route as compared to the other Alternatives, and would affect 2.1 miles more cultivated agriculture and 6.4 miles more rangeland than Alternatives A, B, E and H. However, Alternative D has fewer residences within 500 feet, 0.25 mile and 0.5 mile of the Project than any of the other Alternatives. State land leased for agricultural activities in three locations over four miles along Segment 5 would be impacted by this Alternative. Impacts on recreation would be identical to Alternatives A, B, E and H (none).

Consistency with the Arapahoe County Comprehensive Plan would be identical to Alternatives A, B, E and H.

Table 5-1 Arapahoe County Land Use Impacts by Alternative Alternative Land Use Impact A, B, E, H C, F, G D Length within County (mi.) 13.5 8.4 22.1 Number of Residences within 500 ft. of ROW Centerline 1 1 0 Number of Residences within 0.25 mi. of ROW Centerline 4 4 2 Number of Residences within 0.5 mi. of ROW Centerline 9 12 2 Number of Other Structures within 500 ft. of ROW Centerline 0 5 0 Number of Other Structures within 0.25 mi. of ROW Centerline 4 6 0 Number of Other Structures within 0.5 mi. of ROW Centerline 7 11 0 Length of ROW Parallel to an Existing Transmission Line (mi.) 13.5 2.2 22.0 Length of ROW Parallel to an Existing Transmission Line (% of total Alternative Length) 100.0 26.2 99.5 Length of ROW through Cropland (mi.) 7.3 4.8 9.4 Length of ROW through Cropland (% of total Alternative Length) 54.1 57.1 42.5 Length of ROW through Pasture/Rangeland (mi.) 1 5.7 2.4 12.1 Length of ROW through State Leased Agricultural/Grazing Land 1.0 0 3.0 1All Barren Land, Forest, Wetlands, Shortgrass Prairie and Eastern Plains Shrubland Land Cover assumed to be used for Pasture/Rangeland

Impacts on land use are associated with agricultural operations and ranching. These impacts would be reduced by implementing the following Mitigation Measures:

LU-1: Modify Structure/ROW Location and Construction Timing This mitigation measure will be implemented as necessary to avoid cultivated areas and other land use conflicts where identified by reducing the potential operational and maintenance interference, typically by spanning or micrositing. Construction will also be timed, where practical, to minimize disruption of normal seasonal activities for cropland (planting and harvesting) and rangeland. Construction operations will avoid, to the extent feasible, the disturbance of agricultural soil during period of heavy precipitation.

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LU-2: Match Existing Structure Locations New structures would be sited span-for-span with the existing structures within the limits of standard tower design and in conformance with engineering and PSCo requirements. This mitigation measure will be implemented for Alternatives collocated with existing transmission lines to avoid intermittent structures that impact the operation of agricultural equipment and harvesting patterns.

LU-3: Maintain and Repair Fences, Gates and Other Improvements To minimize impacts on grazing operations, fences and gates will be replaced or repaired to their original condition as required by the landowner in the event that they are removed, damaged, or destroyed by construction activities. Temporary gates or enclosures will be installed only with the permission of the landowner or the land management agency and will be removed following construction. Temporary gates will be kept closed and locked, depending on agreement with the landowners.

LU-4: Coordinated Livestock Management s During Project construction, it may be necessary to relocate livestock from areas where heavy equipment operations are taking place. Arrangements will be made with landowners and livestock owners to keep livestock out of these areas during the specific construction periods.

5.2 Transportation The following discussions describe general transportation impacts that PSCo anticipates for all of the route alternatives in Arapahoe County.

5.2.1 General Impacts

5.2.1.1 Construction Activities As mentioned above, PSCo has prepared a Draft Road Use Agreement for Arapahoe County (Appendix C - Draft Road Use Agreement) in accordance with local, state, and federal requirements for transporting construction materials and overweight/oversize loads on local, state, and federal roads. Implementing the Draft Road Use Agreement would minimize or avoid to the extent possible impacts to the transportation network in and around the Preferred Alternative. The Final Road Use Agreement will identify access road locations and, where necessary, locations where upgraded existing roads and/or new access roads are required. The Final Road Use Agreement will include provisions for construction activities’ hours of operation, potential traffic delays, pilot cars, flagmen, and alternative access routes for the traveling public to use during peak construction periods.

Near the Preferred Alternative, the majority of the roads feature dirt or gravel surfaces, with only the following paved roads:

• Interstate (I) 70 • U.S. Routes, 40, 287, 24 and 36 • State Route 40 • County Route 34/Jolly Road and South Price Road in Arapahoe County • County Road 42/ Wall Road (partial)

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During the construction period, temporary delays may occur on federal, state, and local roads during the movement of oversized/overweight loads. The delays would be expected to last only a few minutes at a time as construction vehicles enter and exit the roads en route to and from construction staging areas and structure work areas. Construction-related impacts to traffic along I-70 and the U.S. and state routes above would be expected to be minimal. These roads are accustomed to handling tractor trailers and other large vehicles and at greater volumes than the unpaved, local roads near the route alternatives. In contrast, construction-related impacts to traffic along local roads would be expected to be moderate, as the road surface condition can reduce driving speeds. While traveling along local roads near the route alternatives, local residents and visitors might experience slightly longer delays as construction vehicles enter, travel along, and exit these roads.

In addition to ground-based construction vehicles, PSCo may use helicopters to transport construction materials to structure work areas, and to string the proposed transmission line’s conductors and shield wires. Prior to commencing these aerial operations, PSCo would coordinate with the FAA’s Denver Flight Service Station to file a flight plan. PSCo would also coordinate with the owners and operators of nearby private airports to ensure that the Project’s aerial transport activities avoid conflicts with aerial spraying operations on agricultural land or other aircraft operations at these private airports.

5.2.1.2 Operation and Maintenance Activities Operating and maintaining the proposed transmission line would not be expected to adversely impact the transportation network near the route alternatives. During maintenance activities, temporary delays may occur as maintenance crews reduce traffic to one lane to perform work on roadside transmission structures and facilities. However, the first scheduled maintenance or inspection activities may occur at least 15 to 20 years after the transmission line is energized.

5.2.2 County Specific Impacts Per the Regulations for Governing Areas and Activities of State Interest in Arapahoe County, the following discussions describe the Project’s anticipated impacts on the transportation network near the route alternatives. The impacts are assumed to be similar for all of the route alternatives in Arapahoe County.

5.2.2.1 Transportation Facilities Required for Existing and Future Land Uses During construction activities, PSCo would rely on the existing road network to the maximum extent practicable; thereby minimizing the need for new access roads in new locations. In Final Road Use Agreement, PSCo will identify existing dirt or gravel roads that might require modifications or upgrades to accommodate construction vehicles’ turning radii and other physical considerations, as well as spur roads from existing roads. It is anticipated that construction activities would not modify existing paved roads. After construction activities are completed, PSCo would work with land owners and county officials to ensure that access roads are returned to pre-construction conditions. PSCo does not anticipate that the Project would substantially impact the existing transportation facilities that local residents use to access existing land uses during construction.

During operation and maintenance activities, it is anticipated that only negligible delays might occur along existing roads as maintenance crews travel to and from transmission structures. The first scheduled maintenance activities would not likely occur for at least 15 to 20 years after the transmission line is

PAGE 83 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

energized. These activities would likely last for only a few hours at a time. PSCo does not anticipate that the Project would substantially impact the transportation facilities that local residents and visitors would use to access future land uses during operation and maintenance activities.

5.2.2.2 Traffic Volume and Level of Service Impacts Given the low-density, sparsely populated area of the county in which the route alternatives would be situated, no substantial impacts would occur to existing and future traffic volumes and Level of Service (LOS). LOS is a qualitative measure used to relate the quality of traffic service. LOS is used to analyze highways by categorizing traffic flow and assigning quality levels of traffic based on performance measures including vehicle speed and volume. LOS is scored using letters from A to F, where A represents the best conditions (free-flow traffic conditions) and F represents failure of the system with excessive delay (failure or breakdown in the traffic system). Roadway corridors that operate at LOS C or better are categorized as uncongested and generally operate in free-flow conditions where drivers can operate at their desired speed without undue delay.

Rural roads in Arapahoe County currently operate at a LOC C or better (Arapahoe County 2010a). Roads near the route alternatives would be expected to continue to operate at or above LOS C during and after Project construction activities. PSCo anticipates that estimated construction traffic during the construction phase of the Project will be 15-20 vehicles per day. PSCo anticipates that construction activities would occur six days per week.

5.3 Visual Resources and Aesthetics

5.3.1 Alternatives A (Preferred Alternative), B, E, and H Impacts on visual resources would occur primarily as a result of contrasts created by the H-frame 345 kV transmission structures that affect visual quality as seen from sensitive viewpoints. In addition to contrasts created from structures, structure contrasts would result in the short-term from the presence of construction equipment such as cranes, graders, concrete trucks, line trucks, and other associated equipment necessary to erect the structures, string the conductors, and access the ROW. Low levels of vegetation and landform contrasts may also result from the clearing of groundcover around structures and to allow access to the ROW. Vegetation contrast would be lower in agricultural areas because production and harvesting would still occur in and around the structures. In areas of rangeland (Shortgrass Prairie/Eastern Plains Shrubland), disturbed areas would be revegetated, and long-term contrasts would be very weak or would not occur. Landform contrasts could occur in steeper areas where road cut or fill is visible, but the majority of the landscape terrain is flat enough that these contrasts would be minimal. Substantial areas of road blading would not likely be necessary due to flat terrain and dominance of low rowing herbaceous vegetation where overland access could occur.

Distance to the Project (Distance Zone: immediate foreground-within 1,000 feet of the Project; foreground- 1,000 feet to 0.5 mile; middleground- 0.5 to 1 mile, background- beyond 1.0 mile), contrast levels (strong, moderate, weak), and landscape or viewer sensitivity (high, moderate, low) affect overall impacts. Strong contrasts seen by a high sensitivity viewer in the foreground would cause higher impacts on visual quality than weak contrasts seen in the middleground by a moderate sensitivity viewer. Visual impacts are identical for Alternatives A, B, E and H because they share the same alignment within

PAGE 84 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

Arapahoe County. An illustration of a typical Project 345 kV Corten steel (self-weathering) structure is shown in Figures 2-3 and 2-4.

Moderate or weak structure contrasts, and weak to no vegetation and landform contrasts would be seen by highly sensitive residences in the immediate foreground in two locations for Alternative A/B/E/H. The Project would be viewed adjacent to an existing (Missile Site to Limon 1) 230 kV transmission line and near the existing Missile Site Substation. The existing 230 kV transmission line is of lower voltage than the Project and has the similar H-frame configuration as the Project structures. The Corten steel finish of the Project structures would be similar, but would be darker brown and of a more uniform texture than existing wood structures, and would more visually dominant. Weak structure contrasts would be seen in the vicinity of the substation due to the multiple transmission lines and substation equipment. Other highly sensitive receptors would also view these Alternatives in the context of the existing 230 kV transmission line in the foreground, middleground and background distance zones. Key Observation Point (KOP) 1, representing immediate foreground and foreground views by residences (Exhibit F), are documented with a photo simulation located in Appendix F showing a photo of the existing Missile Site to Limon 1 230 kV Transmission Line structures.

Sensitive receptors such as visitors and users of the Deer Trail Rodeo Grounds, residences located in Deer Trail, and the Richmil Ranch County Open Space area would not see these Alternatives due to distance and screening by vegetation, landform or built features. Local roads would be paralleled or crossed by these Alternatives, but due to their low sensitivity, low impacts would result. Table 5-2 summarizes visual impacts for alternatives located in Arapahoe County.

The East Bijou Creek corridor would not be visually affected by Alternatives A, B, E and H due to distance from the corridor and terrain.

5.3.2 Alternatives C, F, and G Visual impacts caused as a result of Alternatives C, F and G would be similar to Alternative A/B/E/H in the area of the Missile Site Substation and the two mile shared segment with those Alternatives. Impacts would be moderate to low due to the presence of the existing transmission line and substation infrastructure, with the Project creating moderate to weak contrasts within the immediate foreground and foreground distance zone view of residences. South and east of Deer Trail, these Alternatives would cross ranchland and agricultural landscapes where no transmission line corridors are currently located. The resulting strong structure contrasts, and weak vegetation and structure contrasts would be viewed in the immediate foreground by several residences located west of the Project causing high visual impacts. Alternatives C, F and G would be within about 0.6 miles of Deer Trail residences, and strong structure contrasts would be viewed in the middleground as a result of a new transmission line corridor. Overall, these Alternatives would cause the highest impacts of those located within Arapahoe County due to proximity to the highest number of sensitive viewpoints and number of viewers associated with local and state roads.

5.3.3 Alternative D Visual impacts caused as a result of Alternative D would be similar to Alternatives A, B, E and H in that foreground views would occur from residential areas adjacent to existing transmission line corridors, but structure contrast would be somewhat stronger due to the difference of the existing single pole structures

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and the new H-frame structures relative to structure configuration and visual complexity of the existing structures. However, fewer overall residences would view this Alternative in the immediate foreground, foreground and middleground. Visual impacts occurring in the vicinity of the Missile Site Substation would be similar to the other Alternatives, with the addition of an additional transmission line corridor viewed within the context of the substation infrastructure. Overall impacts would be lower than the other Alternatives due to the fewer number of sensitive viewers in the vicinity of Alternative D. Alternative D would also have the fewest number of residences potentially viewing the Project within the foreground.

Table 5-2 Arapahoe County Visual Impacts by Alternative ALTERNATIVE VISUAL IMPACT A, B, E, H C, F & G D Length within County (mi.) 13.5 8.4 22.1 Number of Residences within 500 ft. of ROW Centerline 1 1 0 Number of Residences within 0.25 mi. of ROW Centerline 4 4 2 Number of Residences within 0.5 mi. of ROW Centerline 9 12 2 Length ROW within Foreground of Interstate, US, or State Highway (mi.) 0 2.2 2.2 Length ROW within Foreground Park or Recreation Area (mi.) 0 0 0

Visual impacts would be reduced by implementing the following Mitigation Measures:

VIS-1: Utilize Non-specular Conductors – This mitigation measure will be implemented to reduce the potential glint and glare associated with standard aluminum conductor (wire).

VIS-2: Match Existing Structure Locations – Project segments that are collocated with existing transmission lines, new structures would be sited near existing structures within the limits of standard tower design and in conformance with engineering and PSCo requirements. This mitigation measure will be implemented to avoid intermittent structures that would otherwise increase structure contrasts.

5.4 Soils, Geology and Natural Hazards

5.4.1 Impacts Common to All Alternatives

5.4.1.1 Soil Erosion Project construction activities affecting soils include permanent and temporary land-disturbance activities such as structure work areas, wire-pulling, tensioning and splicing sites, construction yards, and temporary and permanent access roads. Ground disturbance during construction may increase the potential for erosion, such as removal of protective vegetation may expose soil to potential wind and water erosion. Certain soils within the Project Area would be more susceptible to soil erosion impacts, including soils with high K Factor, low T Factor, and steep slopes. The primary soil erosion factor is water erosion on steep slopes and wind erosion on bare soils.

Potential erosional effects from Project operations would consist of soil disturbances necessary to maintain the transmission lines in working order and conduct necessary repairs. Stormwater BMPs, including erosion and sediment control structures, as well as new culverts would require inspection, maintenance, and repair throughout the operation life of the Project to minimize soil erosion or

PAGE 86 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

sedimentation to surface water. Temporary access roads, not retained for operations, would be seeded with a native grass mix and allowed to revegetate and thereby minimizing the surface exposed to erosive conditions.

The areas used for construction would be reclaimed as soon as possible, which may include regrading to original land contours, topsoil replacement, and revegetation. Implementation of a SWPPP (a CDPHE requirement) and Grading, Erosion, and Sediment Control Plan (GESC, an Arapahoe County requirement), and use of appropriate soil mitigation measures and BMPs would be used to reduce the effects of erosion. The SWPPP and GESC are discussed more fully under the Water Resources and Wetlands section.

The majority of soil types in the eastern areas of the Arapahoe County are rated as slight to moderate erosion hazard primarily due to low to moderate slopes (0 to 15%). There were no slopes over 30% in the ROW for any of the alternatives. These factors indicate that impacts from soil erosion would be similar for all alternatives.

5.4.1.2 Prime Farmland Potential soil impacts to prime farmland, if irrigated from transmission line construction include soil erosion, damage to agricultural drainage systems, mixing of topsoil and subsoil, potential loss of topsoil, and soil compaction. Prime farmland within the construction ROW may be unavailable to agriculture production during the construction period. Prime farmland would be reclaimed as soon as possible, which may include regrading to original land contours, relieving compaction, topsoil replacement, and revegetation.

Although the primary land use activity is farming and ranching, only approximately 30% of the area is considered prime farmland if irrigated or prime farmland if irrigated with other conditions as indicated by NRCS. Prime farmland was not a criteria used for routing because most agricultural activities in this area can be conducted within the proposed transmission line ROW. Due to this factor, impacts to prime farmland would be similar for all route alternatives.

5.4.1.3 Accidental Spills During construction, use of trucks, heavy equipment, or stored supplies could result in accidental discharge of fuel, lubricants, and automotive fluids. Although the potential exists, any spills would be accidental, unlikely due to PSCo’s safety and construction standards, of limited extent, and would be considered minor to negligible and temporary in duration. BMPs for construction housekeeping, spill prevention, and cleanup would be used to prevent and remediate accidental spills. Therefore, accidental spills would not result in widespread or long-term effects to Project soils.

5.4.1.4 Permanent Soil Loss The area within the footprint of each transmission structure would result in minor long-term loss of that acreage to productive soil uses such as for agriculture (because of structures occupying the site); however the implementation of BMPs will avoid any long-term loss of soil.

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5.4.2 End-to-End Route Summary Alternative D would have greater potential for soil erosion and Alternative E would have slightly greater potential for soil erosion, both due to a small percentage of ROW slopes over 30%; otherwise the end-to- end alternatives would have similar potential impacts to soil, geology, and natural hazards. Alternative A, the Preferred Alternative, would have negligible to minor impacts to soil, geology, and natural hazards due to the relatively low to moderate slopes (0 to 15%), ability to conduct agricultural practices under the transmission line, and lack of geologic features and natural hazards.

5.5 Water Resources

5.5.1 Impacts to Surface Water The potential sources of surface water resource impacts from the Project include permanent and temporary soil-disturbance activities from structure work areas, wire-pulling, tensioning and splicing sites, laydown and materials yards, and temporary and permanent roads as well as potential accidental spills of hazardous materials during the construction period. Short-term impacts from soil disturbances that increase erosion (or water runoff in areas with compacted soils) may result in an increase in suspended sediments within adjacent waterbodies and accidental spills of hazardous materials could wash into and pollute surface water; however, the potential impacts to surface water will be negligible and temporary in nature due to the implementation of BMPs to include properly maintaining equipment, storing fuels and petroleum away from excavated areas, cleaning up any spills and spanning water features and drainages.

In addition to soil-disturbance activities, impacts to surface waters may include stream crossings. All of the alternatives within Arapahoe County cross intermittent streams only; no perennial streams will be crossed. All of the intermittent streams will be spanned by the transmission line and individual structures will be located well outside the stream banks to avoid potential impacts. Where available, existing crossings of intermittent streams will be utilized for construction access. Intermittent stream crossings may result in short-term sedimentation impacts to waterbodies from stream bank disturbance and riparian vegetation disturbance and/or removal from the installation of culverts. If culverts are designed or installed incorrectly, they can alter or reduce water flow, change a stream’s hydrodynamics and impede fish passage. If needed, culverts would be designed and installed to ensure the continued free flow of water, as well as to allow both the upstream and downstream movement of aquatic organisms. Culverts may get blocked by debris in streams and cause water to back up and flood areas. As appropriate, any permanent culverts would be inspected, maintained, and repaired regularly throughout the life of the Project to minimize impacts. These activities would be permitted through the applicable agencies.

Stormwater BMPs will be used during construction to reduce potential impacts from erosion, sedimentation, and turbidity in surface waters during construction. A SWPPP and GESC will be developed and implemented for the Project, which will meet the construction stormwater discharge permit requirements of the CDPHE and county GESC requirements. The SWPPP and GESC will include a number of measures to control runoff and to reduce erosion and sedimentation at construction sites. Additionally, the implementation of a SWPPP will also minimize potential impacts. Examples of potential BMPs that may be used includes silt barrier fences to control runoff, sediment traps and basins, and minimizing exposed soils by using temporary and permanent seeding and mulching. All disturbed areas

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will be re-vegetated as requested by landowners. Seed mix and seeding rates will be developed through consultation with the local NRCS and landowner preference.

The construction, O&M of the Project would not contribute to surface water impairments identified by 303(d) listed waterbodies (Big Sandy Creek), which include E. coli and selenium, due to control of stormwater runoff and soil erosion, which will be included in the SWPPP and GESC.

5.5.2 Impacts to Floodplains It is reasonable to assume that all watercourses that convey natural flows, whether mapped as floodplains, flood hazard areas, or not, present some level of flood hazard. Encroachment of a structure into a flood path could result in flooding of or erosion damage to the encroaching structure and diversion of flows. Transmission structures will be set back from channel banks to avoid impacts to floodplains.

5.5.3 Impacts to Ground Water It is unlikely the Project would affect groundwater to any extent. Excavations for transmission line structures may contact shallow groundwater; however, the groundwater contact would be unlikely to adversely impact this resource, unless an accidental spill of fuel or petroleum from construction equipment occurs near an open excavation or is not cleaned up in a timely manner. Techniques to avoid and minimize groundwater impacts would include properly maintaining equipment, storing fuels and petroleum away from excavated areas, fueling in designated areas, and immediately cleaning up any spills before they become a problem. Typically, contact with construction equipment would not impact groundwater quality except to potentially increase turbidity temporarily, and only in a limited area. After application of mitigation measures and BMPs, impacts to groundwater will be negligible.

No water wells would be drilled for the proposed Project. All water used for Project construction will come from existing sources which will be identified and secured prior to construction.

5.5.4 Impacts to Wetlands The potential wetlands identified by NWI will be verified in the field and inventoried and/or delineated to determine the actual locations and extent of wetlands prior to construction of the Project. All wetlands would be spanned by the transmission line to avoid impacts. Wire pulling and tensioning sites will be sited to avoid wetlands to the extent practicable. If wetlands cannot be avoided, matting and other protective temporary measures will be used. Depending on the condition of the wetland soil and hydrology, matting may be used in some cases to protect wetlands from rutting. No permanent loss of wetlands would occur from installation of transmission line structures and conductors.

Increased soil disturbances can lead to the germination of exotic plant species, which can alter the composition and function of wetlands. Impacts could result from soil compaction or alteration of surface or subsurface water movement in wetlands and riparian areas. Failure to restore disturbed areas to their pre-construction conditions (contours, hydrology, segregation, and restoration of topsoil), could impede the re-establishment of wetland vegetation during revegetation and restoration efforts.

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5.5.5 Impacts Common to Alternatives with Forested Wetlands and Riparian Areas Impacts to surface water resources may also result from vegetation disturbance and/or removal within the transmission line ROW. In areas where the transmission line crosses forested riparian areas, trees would be cleared from the width of the ROW. Tree stumps would not be removed to avoid soil erosion. Long- term impacts may result from removal of riparian vegetation may include reduced stream shading, reduced large woody debris input, reduced terrestrial organic input, and increased bank instability and erosion potential. Vegetation removal associated with crossings in forested settings is expected to be localized and minimal, without an overall increase in stream temperatures. In areas where the roots of riparian vegetation are the primary bank stabilizing force, loss of riparian vegetation can result in stream migration. Erosion, sedimentation, and stream instability would be minimized with the use of BMPs and appropriate revegetation activities.

5.5.6 Impacts Common to Alternatives with Geology and Natural Hazards Areas Project construction, operation, and maintenance activities will not impact geologic resources due to lack of points of geological interest in this area and because much of the proposed Project area is considered low risk for geologic hazards. Project activities will not impact natural hazards due to the low occurrence of major landslide and earthquakes as well as the fairly level relief (0-10 percent slope throughout the Project area).

5.5.7 Impacts in Arapahoe County PSCo analyzed eight end-to-end route alternatives (Alternatives A – H) for the entire Rush Creek 345 kV Transmission Line Project. In Arapahoe County the eight end-to-end route alternatives represent three discrete routes due to several of the end-to-end route alternatives sharing common segments in Arapahoe County. A crosswalk of the end-to-end route alternatives and route segments only occurring in Arapahoe County is included below. Impacts are discussed in the Impacts Common to All Alternatives section above. Table 5-3 identifies the water resources and wetlands routing criteria and the numbers for each alternative.

Table 5-3 Water Resources and Wetlands Criteria for Arapahoe County Alternative Routes ARAPAHOE COUNTY ROUTING CRITERIA A, B, E, H C, F & G D Number of perennial stream crossings 0 0 0 Number of intermittent stream crossings 15 9 28 Miles of ROW parallel (within 100 feet) to streams 0 0 0.2 Miles of ROW crossing FEMA designated floodplains 0 0.8 0.2 Number of ROW crossings of Arapahoe County floodplains 7 8 26 Miles of ROW crossing NWI wetlands 0 0.3 0.2 Miles of ROW crossing playa lakes 0 0 0

5.5.7.1 Preferred Alternative A and Alternatives B, E, and H Alternatives A, B, E, and H share common route segments in Arapahoe County and will share identical potential impacts from the proposed Project. The impacts for water resources and wetlands are discussed below.

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Surface Water Alternatives A, B, E and H do not cross any perennial streams, crosses 15 intermittent streams, and do not cross FEMA-designated floodplains, but do cross 15 Arapahoe County-regulated floodplains. The number of intermittent stream crossings is greater than Alternatives C, F, and G, but are lower than Alternative D. The potential impacts will be negligible to minor due to the ability to span water features and avoid impacts during construction.

Wetlands The alternatives do not cross NWI wetlands or playa lakes. These represent smaller numbers than the other two alternatives. The potential impacts to wetlands will be negligible to minor due to the ability to span wetland features and avoid impacts during construction.

Floodplains The alternatives do not cross FEMA mapped floodplains. The alternatives cross seven unmapped Arapahoe County defined floodplains. The total liner feet of Arapahoe County defined floodplains crossed is 632-feet. The shortest crossing is 29-feet and the longest crossing is 159-feet. A Floodplain Analysis Report was prepared and submitted as an accompanying dociument to this Application.

5.5.7.2 Alternatives C, F, and G Alternatives C, F, and G share common route segments in Arapahoe County and will share identical potential impacts from the proposed Project. The impacts for water resources and wetlands are discussed below.

Surface Water These alternatives cross no perennial streams, nine intermittent streams, and 0.8 mile of FEMA- designated floodplain, which is associated with East Bijou Creek. These alternatives also cross eight Arapahoe County regulated floodplains.

Wetlands These alternatives cross 0.3 mile of NWI wetlands and no playa lakes. Aside from one small PEM and one R4 wetland (First Creek), all of these NWI wetlands are associated with East Bijou Creek, including PFO, PSS, and R4 wetlands.

Floodplains The alternatives cross 0.8 miles of FEMA mapped floodplains. The alternatives cross eight unmapped Arapahoe County defined floodplains.

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5.5.7.3 Alternative D

Surface Water Alternative D would cross no perennial streams, 28 intermittent streams, 0.1 mile of playa lakes, and 0.2 mile of FEMA-designated floodplain, which is associated with Muddy Creek. This alternative also crosses 26 Arapahoe County regulated floodplains.

Floodplains The alternatives cross 0.2 miles of FEMA mapped floodplains. The alternatives cross 26 unmapped Arapahoe County defined floodplains.

5.6 Biological Resources In Arapahoe County, the eight end-to-end route alternatives represent three discrete routes due to several of the end-to-end route alternatives sharing common segments in Arapahoe County. A crosswalk of the end-to-end route alternatives and route segments only occurring in the County is in Table 5-4, which identifies the biological resources routing criteria crossed by all the alternatives in the County.

Table 5-4 Arapahoe County Biological Resource Impacts by Alternative Routes ALTERNATIVES BIOLOGICAL RESOURCES IMPACTS A, B, E, H¹ C, F, G¹ D¹ Length of ROW across known habitat of federally listed endangered or 0.0 0.0 0.0 threatened species Length of ROW across known habitat of state listed endangered or 0.0 0.0 0.0 threatened species Length of ROW across known raptor species nest or nest buffer 0.0 0.0 0.0 Length of ROW across developed land 2.0 3.3 0.6 Length of ROW across mixed woodland 0.0 0.0 0.0 Length of ROW across shortgrass prairie 5.7 2.0 12 Length of ROW across eastern plains shrubland 0.0 0.0 0.1 Length of ROW through cropland/pasture 7.3 4.8 9.4 Length of ROW across open water (lakes, ponds) 0.0 0.0 0.0 Length of ROW across playa lakes 0.0 0.0 0.0 Number of ephemeral stream crossings 0 0 0 Number of perennial stream crossings 0 0 0 Number of intermittent stream crossings 15 9 28 Number of river crossings 0 0 0 Length of ROW parallel (within 100 feet) to streams or rivers 0.0 0.0 0.2 ¹ The length is calculated in miles

5.6.1 Alternatives A (Preferred Alternative), B, E, and H Alternatives A, B, E, and H share common route segments in Arapahoe County and will share identical potential impacts from the Project. Below is the biological impact analysis for the portions of Alternatives A, B, E, and H with shared route segments.

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5.6.1.1 Terrestrial and Aquatic Wildlife (Alternative A (Preferred), B, E, and H)

Wildlife and Wildlife Habitat Wildlife species that may occur within the Project Area include those adapted to the habitats present. A diverse species composition is anticipated given the range of habitat identified within the Project Area however, species may be limited due to the extent of residential, cropland, and rangeland development. The primary impacts of construction activities on terrestrial wildlife species are typically associated with temporary disturbances from construction activities, and with the removal of vegetation (habitat modification/fragmentation) within the 150-foot ROW. Increased noise and equipment movement during construction may temporarily displace mobile wildlife species from the immediate workspace area. These impacts are considered short-term in duration and normal wildlife movements would be expected to resume after construction is completed. Potential long-term impacts include those resulting from habitat modifications and/or fragmentation. During the routing process, PSCo attempted to minimize potential habitat fragmentation by paralleling existing linear features and avoiding paralleling streams to the extent feasible.

Construction activities might also impact small, immobile, or fossorial (living underground) animal species through incidental takes or from the alteration of local habitats. Incidental takes of these species might occur due to equipment or vehicular movement on the ROW by direct impact or due to the compaction of the soil if the species is fossorial. Potential impacts of this type are not typically considered significant and are not likely to have an adverse effect on any species population dynamics.

It is anticipated that increased noise and human activity during construction will discourage wildlife from entering Project work sites. Additionally, implementation of the following BMPs will minimize the potential for injury or death to wildlife:

• Providing environmental awareness training to all construction personnel working on the Project. • Properly disposing of trash and food debris in secured containers. • Allowing wildlife that has entered the work area to leave the area on their own. • Checking for wildlife under vehicles and equipment that have been stationary for more than one hour and each morning prior to moving or operation. • Checking trenches, excavations, and uncapped pipe segments for wildlife. • Installing escape ramps at night. • Complying with posted speed limits. • Prohibiting firearms or pets at Project work sites.

The construction of the project is not anticipated to have any effect on species in this area. If any potential suitable habitat for threatened endangered species is identified during a field survey of the Preferred Alternative, PSCo will further coordinate with USFWS and CPW to determine avoidance or mitigation strategies.

Raptors and Migratory Birds No known raptor species nest or associated nest buffers are crossed by Alternatives A, B, E, and H. PSCo proposes to complete all ROW clearing and construction activities in compliance with the Migratory Bird Treaty Act (MBTA) to avoid or minimize potential impacts. If ROW clearing occurs during bird nesting season, potential impacts could occur within the ROW area related to migratory bird eggs and/or

PAGE 93 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

nestlings. Increases in noise and equipment activity levels during construction could also potentially disturb breeding or other activities of bird species nesting in areas adjacent to the ROW.

Transmission lines can also present additional hazards to birds due to electrocutions and/or collisions. Measures can be implemented to minimize this risk with transmission line engineering designs. The electrocution risk to birds should not be significant since the engineering design distance between conductors, conductor to structure, or conductor to ground wire for the proposed 345 kV transmission line is greater than the wingspan of any bird potentially within the area (i.e., greater than eight feet). While the conductors are typically thick enough to be seen and avoided by birds in flight, the shield wire is thinner and can present a risk for avian collision. This risk can be minimized by installing bird flight or swan diverters or other marking devices on the line within high bird use areas. PSCo will coordinate with USFWS on the installation of bird flight or swan diverters or other marking devices as determined necessary for specific locations.

Measures to protect migratory birds and their habitats include:

• Conducting tree/vegetation clearing outside the nesting season (generally considered to be April 15 to August 1), where feasible, to discourage birds from establishing nests in Project work areas. • Conducting pre-construction nest surveys prior to initiating construction activities, unless vegetation clearing has been completed prior to the nesting season.

If migratory bird nests are identified and activities that may disturb migratory bird habitat are unavoidable during the nesting season, protective measures to be implemented may include:

• Notifying the USFWS of the location of the nest(s) and determining appropriate site- specific protection measures, as necessary, in consultation with the USFWS and/or applicable state resource agency. • Retaining a qualified biologist to monitor active nests and the associated birds’ behavior. • Establishing an appropriate buffer zone around the nest, as necessary, in consultation with the USFWS and/or applicable state resource agency. • Suspending construction within the designated protective buffer zone until the young have fledged or until further instruction is given by the applicable agency. Personnel vehicles will still be allowed to travel along existing access roads that may fall within the active nest buffer zone.

Aquatic Wildlife Fifteen intermittent streams are crossed by Alternatives A, B, E, and H. Potential impacts to aquatic systems would include effects of erosion, siltation, and sedimentation. Clearing the ROW of vegetation might result in increased suspended solids in the surface waters traversed by the transmission line. Increases in suspended solids might adversely affect aquatic organisms that require relatively clear water for foraging and/or reproduction. Physical aquatic habitat loss or alteration could result wherever riparian vegetation is removed and also at temporary crossings required for access roads. Increased levels of siltation or sedimentation might also potentially impact downstream areas, primarily affecting filter feeding benthic and other aquatic invertebrates.

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To avoid or minimize these impacts, PSCo proposes to span all surface waters, riparian areas, and wetlands to the extent feasible. Temporary and permanent impacts to wetland vegetation will occur; however, refer to the Water Resources section for details on BMPs that will be implemented. Additionally, the implementation of a SWPPP will also minimize potential impacts. Therefore, no significant adverse impacts are anticipated to any aquatic habitats crossed or located adjacent to the ROW for any of the alternative routes.

Federal and State Listed Species No known occurrences of any federal/state listed threatened or endangered plant or animal species or designated critical habitat areas were identified along Alternatives A, B, E and H within Arapahoe County, refer to Table 4-2. The construction of the project is not anticipated to have any effect on listed species in this area. If any potential suitable habitat for threatened endangered species is identified during a field survey of the Preferred Alternative, PSCo will further coordinate with USFWS to determine avoidance or mitigation strategies.

5.6.1.2 Terrestrial and Aquatic Plant Life (Alternative A (Preferred), B, E, and H) Potential impacts to vegetation within Alternative A, B, and H would result from clearing the ROW of cropland (approximately 7.3 miles), short-grass prairie (approximately 5.7 miles) and developed lands (approximately 2.0 miles, refer to Table 5-4. These activities facilitate ROW access for structure construction, line stringing, and future maintenance activities of the proposed transmission line. Impacts to vegetation would be limited to the150-feet wide ROW. ROW clearing activities would be completed while minimizing the impacts to existing groundcover vegetation when practical. Mowing and/or shredding of herbaceous vegetation might be required within grasslands/pasturelands. Future ROW maintenance activities might include periodic mowing and/or herbicide applications to maintain the herbaceous vegetation layer within the ROW. Measures to minimize vegetation-related impacts (in addition to the measures previously identified to minimize impacts on wildlife habitat and covered under Water Resources for wetlands) include:

• Restoring contours and seeding temporary disturbance areas following final grading (unless otherwise specified by local resource agencies), weather and soil conditions permitting. • Preparing a seedbed to a depth of three to four inches using appropriate equipment. • Adhering to recommended seed mixes, application methods and rates, and timing windows provided by local resource agencies.

Disturbance related to construction or maintenance activities has the potential to generate infestations of noxious weed species, particularly if vegetation is cleared. During re-growth, the native species will be competing to re-establish at the same time that the noxious weed species are attempting to dominate the cleared area. Soils and mud on vehicle and equipment tires, tracks, and undercarriages have the potential to carry and disperse weed seeds. Invasive and/or non-native species can then be spread along access roads and Project work areas, increasing the likelihood of introducing new populations or increasing existing populations. The potential for the introduction and/or spread of invasive non-native species (including noxious weeds) will be minimized by implementing the following best management practices BMPs:

• Ensuring all construction equipment is cleaned prior to beginning work on the Project.

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• Requiring the construction contractor to use certified weed-free straw or hay bales for sediment barrier installations and/or mulch. • Using certified weed-free seed mixes for post-construction revegetation. • Controlling noxious weeds within the ROW using mechanical or herbicide application, as necessary. • Adhering to applicable invasive species management practices in accordance with federal, state, and local regulations. • Removing excess dirt and mud from equipment and vehicles prior to leaving areas with noxious weed populations.

5.6.2 Alternatives C, F, and G Biological resources impacts on terrestrial and aquatic wildlife would be similar for Alternatives C, F and G as they are for Alternatives A, B, E, and H, but would occur in a different area. Impact on terrestrial and aquatic species would be identical to Alternatives A, B, E, and H. This Alternative crosses 9 intermittent streams. Surface water is present for brief periods (from a few days to a few weeks) during the growing season, but the water table usually lies well below the ground surface for the most of the season. To avoid or minimize these impacts, PSCo proposes to span all surface waters and wetlands to the extent feasible. Additionally, the implementation of a SWPPP and BMPs will also minimize potential impacts. Therefore, no significant adverse impacts are anticipated to any aquatic habitats crossed or located adjacent to the ROW for Alternatives C, F, and G.

No known raptor species nest or associated nest buffers are crossed by these alternatives. PSCo proposes to complete all ROW clearing and construction activities in compliance with the MBTA to avoid or minimize potential impacts.

No known occurrences of any federal/state listed threatened or endangered plant or animal species or designated critical habitat areas were identified along any of the alternative routes within Arapahoe County, please refer to Table 4-2. If any potential suitable habitat for threatened endangered species is identified during a field survey of the Preferred Alternative, PSCo will further coordinate with USFWS to determine avoidance or mitigation strategies.

Alternatives C, F, and G would primarily cross existing disturbed areas such as cropland for approximately 4.8 miles. The total length of the ROW through shortgrass prairie would be less, approximately 2.0 miles; however, these Alternatives do not parallel existing transmission lines except along a 2.2 mile section immediately south of the Missile Substation. Impact on terrestrial and aquatic plant life would be identical to Alternatives A, B, E, and H.

5.6.3 Alternative D Biological impacts on terrestrial wildlife and aquatic species would be similar to Alternatives A, B, E, and H, but these impacts would occur over greater distance for Alternative D. This Alternative crosses 28 intermittent streams. To avoid or minimize these impacts, PSCo proposes to span all surface waters and wetlands to the extent feasible. Additionally, the implementation of a SWPPP and BMPs will also minimize potential impacts. Therefore, no significant adverse impacts are anticipated to any aquatic habitats crossed or located adjacent to the ROW for Alternative D.

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No known raptor species nest or associated nest buffers are crossed by Alternative D. PSCo proposes to complete all ROW clearing and construction activities in compliance with the MBTA to avoid or minimize potential impacts. This would include conducting tree/vegetation clearing outside the nesting season (generally considered to be April 15 to August 1), where feasible, to discourage birds from establishing nests in Project work areas and conducting pre-construction nest surveys prior to initiating construction activities, unless vegetation clearing has been completed prior to the nesting season.

No known occurrences of any federal/state listed threatened or endangered plant or animal species or designated critical habitat areas were identified along Alternative D within Arapahoe County, refer to Table 4-2. If any potential suitable habitat for threatened endangered species is identified during a field survey of the preferred route, PSCo will further coordinate with USFWS to determine avoidance or mitigation strategies.

Alternative D crosses 9.4 miles of cropland/pasture/rangeland, 12 miles of shortgrass prairie, and 0.1 mile of shrubland. Impact on terrestrial and aquatic plant life would be identical to Alternatives A, B, E, and H.

5.7 Paleontological and Cultural Resources Identifying areas of high site potential is usually identified through the presence of previously identified archaeological sites or historic structures. However, due to the relatively sparse amount of previous cultural resource inventories in this part of Arapahoe County, this is not a reliable method. Instead, high probability areas were identified through the analysis of surrounding areas and topographic features in surrounding areas where more thorough cultural investigations have been undertaken.

POWER determined several criteria that would make a specific landform more likely to contain an archaeological site. For this Project this includes:

1) Proximity to a permanent or seasonal water source (up to 1 mile). 2) Relatively flat or gently rolling terrain above or along a major water source. 3) Landforms that are outside areas of previous ground surface disturbance. A high probability area may include one or all of the above criteria (see Figure 5-1). Potential impacts to cultural resources along the Alternative Routes may include direct physical disturbance from heavy equipment, construction activities, and unmanaged erosion. Impacts may also include indirect visual disturbances caused by the visual intrusion of new transmission line infrastructure in the view shed of significant cultural resource. Mitigation for these potential impacts would be primarily met by avoidance of all cultural resources by the project design and regular monitoring of construction activities near known significant cultural resources. Visual impacts may be mitigated through structure design or through consultation with the Colorado SHPO and interested parties to determine acceptable levels of visual impacts to the significant cultural resources along the Alternative Routes.

5.7.1 Arapahoe County PSCo analyzed eight (8) end-to-end route alternatives (Alternatives A – H) for the entire Rush Creek Connect 345 kV Project. In Arapahoe County, the eight end-to-end route alternatives represent three discrete segments due to several of the end-to-end route alternatives sharing common segments in

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Arapahoe County. High probability segments are described below for the Project alternatives. See Table 5-5 for Cultural Resource Impacts by Alternative.

5.7.1.1 Alternatives A (Preferred Alternative), B, E, and H Alternatives A, B, E, and H share common route segments in Arapahoe County. Within Arapahoe County, high probability areas in Segments 1 and 2 are located on a large relatively high up-lift above First Creek. However, a majority of these two segments are within cultivated fields making them less likely to contain undisturbed cultural resources. Within Arapahoe County, high probability areas within Segment 4 run east and stay within the rolling hills and ridges east of Bijou Creek. This segment crosses the upper reaches of Bolden Gulch and the unnamed seasonal tributaries of Muddy Creek. Near the Arapahoe county line this segment runs along the first terraces above Muddy Creek itself. Approximately 6 miles of Segment is considered to be high probability areas for cultural resources.

5.7.1.2 Alternatives C, F, and G Alternatives C, F and G share common route segments in Arapahoe County. High probability areas within Segments 1 and 2 are located on a large relatively high up-lift above First Creek. However, a majority of these two segments are within cultivated fields making them less likely to contain undisturbed cultural resources. Segment 3 runs south across First Creek and south across the terrace slopes and flood plain of Bijou Creek. Nearly all parts of this segment in Arapahoe County are considered high probability areas.

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Approximately 2.5 miles of this route is cultivated. These areas may contain sites but they are more likely to be dispersed or disturbed.

5.7.1.3 Alternative D Within Alternative D Segment 5 is a high probability area that heads east from the Missile Silo Substation across rolling hills and flat terraces above Bolden Gulch, Muddy Creek, Badger Creek, Cottonwood Creek, and Rattlesnake Creek. Only a small portion of these landforms have not been cultivated leaving approximately 3 miles of high probability areas for cultural resources.

Table 5-5 Cultural Resource Impacts by Alternative – Arapahoe County Alternative Cultural Resource Impact A B C D E F G H Number of recorded historic or prehistoric sites 0 0 1 0 0 1 1 0 crossed by ROW Number of additional recorded historic or prehistoric 0 0 1 0 0 1 1 0 sites within 1,000 feet of ROW centerline Number of National Register listed or determined 0 0 1 0 0 1 1 0 eligible sites crossed by ROW Number of additional National Register listed or determined eligible sites within 1,000 feet of ROW 0 0 1 0 0 1 1 0 centerline Length of ROW through areas of high 6 6 2.5 3 6 2.5 2.5 6 archaeological/historic site potential

5.7.2 End-to-End Route Summary

5.7.2.1 Alternative A (Preferred Route) Alternative A is a generally low impact route that crosses the lowest number of previously recorded sites and only 43 miles of high site potential areas. This route would likely represent a lower potential impact to significant cultural resources.

5.7.2.2 Alternative B Alternative B is similar to Alternative A in many aspects including most of its route and its potential impacts to cultural resources. Alternative B only crosses one cultural resource and 43 miles of high site potential areas. This route would likely represent a lower potential impact to significant cultural resources.

5.7.2.3 Alternative C Alternative C covers more miles of high potential site areas, approximately 53.5, and crosses and passes within 1,000 meters of 11 previously recorded cultural resources including the NRHP listed Union Pacific Railroad Segment and the Beuck Land Company Centennial Farm. The Union Pacific Railroad Segment is not likely to be significantly impacted by visual disturbances and should be spanned to avoid any direct impacts. The Centennial Farm does contain significant historic structures that may require indirect visual impact mitigation.

PAGE 101 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

5.7.2.4 Alternative D Alternative D crosses or is within 1,000 feet of 24 previously recorded cultural resources. It does however cross only 42 miles of high site potential areas, the lowest of the alternatives. Alternative D crosses site 5LN477, an NRHP eligible prehistoric site that would require avoidance of direct impacts or monitoring during construction near the site boundary.

5.7.2.5 Alternative E Alternative E crosses or is within 1,000 feet of seven previously recorded cultural resources none of which are eligible for the NRHP. Alternative E crosses a total of 49 miles of high site potential areas.

5.7.2.6 Alternative F Alternative F crosses or is within 1,000 feet of 17 cultural resources including the Beuck Land Company Centennial Farm and a Union Pacific Railroad Segment. Alternative F also crosses 64.5 miles of high site potential areas the largest of the Alternatives. The Union Pacific Railroad Segment is not likely to be significantly impacted by visual disturbances and should be spanned to avoid any direct impacts. The Centennial Farm does contain significant historic structures that may require indirect visual impact mitigation.

5.7.2.7 Alternative G Alternative G crosses or is within 1,000 feet of 12 previously recorded cultural resources including the Beuck Land Company Centennial Farm and a Union Pacific Railroad Segment. Alternative G also crosses 53.5 miles of high site potential areas. The Union Pacific Railroad Segment is not likely to be significantly impacted by visual disturbances and should be spanned to avoid any direct impacts. The Centennial Farm does contain significant historic structures that may require indirect visual impact mitigation.

5.7.2.8 Alternative H Alternative H crosses or is within 1,000 feet of 7 previously recorded cultural resources none of which are eligible for the NRHP. Alternative G also crosses 57 miles of high site potential areas.

5.8 Air Quality and Controls The existing air quality in the region is typical of rural agricultural regions in the western United States. There is limited data collected in similar areas; however, the data collected indicate that ambient pollutant levels are typically near or below detection limits. Areas subject to poorer air quality are those sites immediately adjacent to surface-disturbing activities such as energy, oil, and gas development projects; farm tilling; and local population centers affected by residential emissions.

5.8.1 Existing Emission Sources In the Project Area, air quality is primarily affected by emissions from energy development and production activities. Additional sources include agricultural activities such as planting and harvesting, sand and gravel quarries, automobiles, and small to medium-sized generators. These sources typically generate

PAGE 102 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

and emit carbon monoxide (CO), nitrogen oxides (NOx), particulate matter less than 10 microns (PM10),

particulate matter less than 2.5 microns (PM2.5), sulfur dioxide (SO2), and volatile organic compounds (VOCs). With the removal of leaded gasoline in the marketplace and the absence of industries such as non-ferrous smelters and battery plants, airborne lead pollution is not an issue of concern in the area (CDPHE 2016).

5.8.2 Attainment Status In 2008, the State of Colorado recommended that the Denver Metro/North Front Range 8-hour nonattainment area be designated as nonattainment for the 2008 revised 8-hour ozone standard. The 8- hour ozone nonattainment area consists of a nine-county area that includes Arapahoe County. Elbert and Lincoln Counties have not been designated as nonattainment (CDPHE 2009).

The air quality in the eastern area of Arapahoe County where the Project Area is located is generally considered to be very good. For all criteria pollutants except ozone, the air quality is considered to be in attainment or unclassified. An unclassified designation indicates that the status of attainment has not been verified through data collection. For the purposes of permitting new sources, unclassified areas are considered to be in attainment.

5.8.3 Applicable State Requirements The proposed Project does not have any long-term emission sources planned. Project-related air emissions will be short-term and primarily occur during construction activities. The Project will not significantly affect air quality.

The CDPHE – Air Pollution Control Division (APCD) implements and enforces the federal Clean Air Act permitting program and air quality standards in Colorado. Under Colorado air quality regulations, land development includes all land clearing activities such as excavating or grading for residential, commercial, or industrial development. These land disturbing activities release fugitive dust which is regulated by the APCD.

Land development projects greater than or equal to 25 continuous acres and/or 6 months in duration typically require the submission of an Air Pollutant Emission Notice (APEN) and an air permit. The APEN will document the general project information such as project description, location, size, and duration. In addition, the APEN will include detailed information on the Project’s Fugitive Dust Control Plan.

5.8.4 Construction Emissions The large equipment used during construction will likely be powered with diesel fuel or gasoline. The

combustion of these fuel sources include pollutants such as NOx, CO, VOCs, particulate matter (PM),

small amounts of SO2, and trace amounts of hazardous air pollutants. It is assumed that all equipment used for the project will be maintained to comply with all emissions standards. Therefore, air quality impacts associated with construction of the Project will primarily be limited to fugitive dust.

Fugitive dust arises from land clearing, grading, excavation, and vehicle traffic on unpaved roads. The amount of fugitive dust depends on the amount of vehicular traffic, construction activities, moisture content of the soil, and wind speed. During dry periods with high winds, fugitive dust would be much more

PAGE 103 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

prevalent that during wet periods with low winds. Dust suppression methods such as watering will be used in construction zones during dry periods to minimize fugitive dust impacts.

As the fugitive dust emissions and emissions from combustion engines will be temporary (limited to the construction period) and will be transient, these sources will not significantly contribute to the ozone levels in Arapahoe County.

5.8.5 Operational Emissions During operations of the Project, the primary emissions are expected to be fugitive dust from worker and maintenance vehicles traveling on unpaved roads. In addition, there will be emissions from vehicles or maintenance equipment. No significant emissions are anticipated and, therefore, no impacts to air quality are anticipated during the operation of the Project.

5.8.6 Mitigation Measures Mitigation measures will be implemented to minimize any potential impacts to air quality from construction activities.

Project emissions are only anticipated to arise from ground disturbing activities, equipment movement, and fuel combustion. These emissions will be temporary and localized. Mitigation measures to address construction-related impacts will consist of:

• Maintaining all fossil fuel-fired construction equipment in accordance with manufacturers’ recommendations to minimize construction-related combustion emissions. • Controlling combustion emissions through engine manufacturing requirements for both mobile sources (40 CFR Part 85) and portable equipment such as air compressors. • Limiting the idling time of equipment to no more than five minutes, unless idling must be maintained for proper operation (e.g., drilling, hoisting, and trenching). • Limit the speed of vehicles within construction sites and along the utility ROW during construction to reduce the amount of fugitive dust generated. • Water trucks will be utilized as necessary to reduce fugitive dust from construction activities.

5.9 Noise, Vibration, Odors, and Nuisances The existing noise levels in the Project Area of rural Arapahoe County are relatively low. The primary existing sources of noise in the Project Area are traffic along local county roads and some agricultural machinery. Vibration, odors, or other nuisances from the Project are not anticipated, except for minimal noise associated with equipment operation during the construction period and maintenance activities. The noise impacts will be temporary in location and duration and all applicable state and local noise regulations will be complied with. After construction, operating noise emanating from the transmission line will in compliance with Colorado PUC noise limits. The Project will not contribute to odor impacts in Arapahoe County.

The Rush Creek 345 kV Transmission Line Project will also be in compliance with Colorado PUC requirements regarding electromagnetic field (EMF) levels around the transmission line. The Colorado

PAGE 104 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

PUC EMF limits are 150 milligauss at the edge of ROW, one-meter above ground. The Project’s transmission line alignments have been designed to limit potential human exposure to EMF. The selection of Alternative A as the Preferred Alternative has limited potential human expose to EMF since it has limited populations around the ROW.

5.10 Socioeconomics The following discussions describe general socioeconomic impacts that PSCo anticipates for all of the transmission route alternatives in Arapahoe County, and considers construction labor costs, monetary capital, and material and consumer resources. There are no mitigation measures applicable to socioeconomic impacts.

5.10.1 General Impacts PSCo anticipates that most of the Project’s socioeconomic impacts would provide minor, direct and indirect benefits to local and regional economies during short-term construction activities and negligible benefits during long-term O&M activities, as described below. These benefits would likely be similar for all of the transmission route alternatives because all of the alternatives would occur in and around the same communities. The alternatives’ route lengths, ROW and access road requirements do not factor into socioeconomic impacts in the quantitative way they would for land use and natural and cultural resources’ impacts.

5.10.1.1 Construction Activities During the Project’s construction period, the local and regional population may experience a minor increase. For the alternatives within Arapahoe County, PSCo anticipates that most of the construction workers would be long-term Denver-Aurora-Lakewood, Colorado Metropolitan Statistical Area (Denver MSA) residents and some out-of-area specialty workers. The Denver MSA includes Arapahoe County. Many of these resident workers would possess the construction skills and experience needed for the Project, while others may require on-the-job training. These resident workers would likely have established incomes, and their short-term employment on the Project would not add substantial new revenue streams to the local and regional economies. The remainder of construction workers would be expected to originate from locations outside of the Denver MSA, possibly from other parts of Colorado or from out-of-state. These workers would temporarily relocate to the Denver MSA during the construction period.

As some construction workers temporarily relocate to the Denver MSA, it is anticipated that these workers would provide direct and indirect benefits to the economies in these areas. Direct benefits would include purchasing goods, services, and short-term housing arrangements. The purchases would increase local and regional business revenues and associated state and local tax revenues. While a portion of the workers’ incomes would be spent on such purchases, most of their incomes would be transferred to their spouses/families at their permanent residences to pay for housing and other cost-of-living expenses. The workers would be expected to provide indirect benefits as their demand for goods and services might prompt local and regional businesses to hire more staff and/or order more supplies. Additional staff would spend a portion of their incomes on local and regional goods, services, and housing; and ordering supplies from non-local or non-regional wholesalers would provide economic benefits to the wholesalers’

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communities. In this way, construction workers’ initial purchases create a ripple effect that can extend far beyond the communities near the Project.

Construction activities would also be expected to have a minor benefit on local and regional economies in reducing unemployment rates and the stock of vacant short-term housing units. The indirect benefits mentioned above might reduce unemployment rates as convenience stores and gas stations, grocery stores, restaurants, shops, and lodging establishments hire more staff to accommodate the non-resident workers’ demand for goods, services, and shot-term housing. As some workers temporarily relocate to the communities near the Project, they would increase the demand for housing, including vacant single- family housing units and/or hotel/motel rooms. This increase in demand would provide a short-term benefit to local and regional real estate markets in the form of short-term rental payments and guest room fees and taxes.

Construction Labor Costs Concerning construction labor costs, it is important to note the average wages for construction workers in Colorado, as PSCo anticipates that workers in and around the Denver MSA would compose the majority of the work force. The average wages for construction workers yields $29.83 per hour (Colorado Department of Labor and Employment 2015). Using this wage and assuming that PSCo would employ between 12 and 30 workers during the construction period. Construction workers would spend a portion of this money to purchase the consumer resources listed below.

Material and Consumer Resources For purposes of the Project, material resources would be expected to include, but are not limited to:

• Corten (self-weathering steel) for the transmission poles. Note that self-weathering steel for the transmission poles will be sourced from suppliers outside of the Denver MSA. • Aluminum and steel for the conductors. • Steel for the OPGWs. • Transformers and other electrical equipment. • Cement for substation component foundations. • Fill material, if not available near the work area. • Gravel for construction yards/staging areas and roads. • Office trailers for construction yards/staging areas. • Gasoline and diesel fuel for the construction equipment and vehicles mentioned above.

Consumer resources are those that construction workers would require, and include, but are not limited to:

• Food, including groceries and meals at eating and drinking establishments. • Lodging at hotels, motels, campgrounds, or for rent housing units. • Emergency services, including police, fire, and rescue. • Medical, dental, and other health-related services. • Laundry services. • Banking and postal services. • Automotive services. • Arts, entertainment, shopping, and retail trade services.

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In contrast to the construction activities’ benefits, the Project might cause short-term, minor, adverse impacts to the local and regional economies if construction contractors purchase material resources from vendors outside of the Denver MSA. Purchasing material resources from outside vendors would help fund economies elsewhere instead of circulating funds in the local and regional economies. Additionally, as these resources are purchased elsewhere, the decreased demand for local and regional materials might prompt suppliers to reduce staff hours or postpone hiring more staff. This phenomenon could prolong existing unemployment conditions or potentially increase unemployment rates. Construction contractors would choose outside vendors if local or regional vendors do not have enough materials and supplies available and/or the local or regional prices are greater than those from outside vendors.

PSCo would purchase some material resources from suppliers outside of the Denver MSA. However, PSCo would purchase many other material resources, including rock, aggregate, cement, asphalt, and fuel from local and/or regional suppliers; thereby providing direct and indirect benefits to local and/or regional economies. Additionally, construction workers’ expenditures on food, fuel, lodging, and the other consumer resources listed above would provide similar direct and indirect benefits to the local and/or regional economies.

5.10.1.2 Operation and Maintenance Activities PSCo anticipates that the Project’s O&M activities would provide slight socioeconomic benefits to the local and regional economies. More specifically, the Project’s permanent O&M workers would represent a small fraction of the temporary construction work force. It is anticipated that the Project would require fewer than 5 permanent, full-time O&M workers for the substation and transmission line. Many of these O&M workers would likely have resided in the Denver MSA for many years and would likely have worked in the electric power transmission industry performing the same or similar O&M tasks. It is anticipated that these workers’ salaries would not substantially increase or decrease from their current levels and their housing requirements would not substantially change.

During scheduled power outages and/or emergency situations, O&M workers might purchase job-related supplies from local or regional businesses and thereby increase local or regional business revenues and associated state and local tax revenues. However, given that scheduled maintenance activities would not occur for at least 15 to 20 years after the transmission line is energized, these increases would represent negligible benefits. A few O&M workers, who did not reside in the Denver MSA prior to the Project, might permanently relocate to the area for O&M employment. The workers’ impact on the local or regional economies would also be negligible. For all of these reasons, the Project’s O&M activities would provide only negligible socioeconomic benefits to the local and regional economies.

5.10.2 County-Specific Impacts Per the Regulations for Governing Areas and Activities of State Interest in Arapahoe County, the following discussions describe the Project’s anticipated impacts on the local economy, the net effect of the Project on the local economy, and opportunities for economic diversification, including the number and types of jobs that the Project would create. Among the transmission route alternatives, it is assumed that there would be no noticeable difference in socioeconomic impacts.

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5.10.2.1 Description of Impacts

Population The Project’s temporary influx of workers who relocate for construction employment would have no noticeable impact on the county’s 2015 population of 631,096 residents. The majority of this population lives in the greater Aurora area with comparatively smaller populations residing in Byers, Deer Trail, and Strasburg. It is assumed that most of the workers who relocate would live in Aurora. For the remainder of these workers who choose to live in these smaller communities, their impact on these communities’ populations would not likely represent a substantial change from existing conditions.

During the Project’s O&M activities, there would be no noticeable impact on the county’s population. Most of the O&M workers would likely be long-term county residents. Should a few workers relocate to the county for O&M employment, they would have no noticeable impact on the county’s population.

Employment and Income The Project’s temporary workers who relocate for construction employment would have no noticeable impact on the county’s number of employed civilian laborers. These workers would increase the county’s number of workers but would not help to reduce the unemployment rate unless local businesses hire additional staff to accommodate these workers’ increased demands for goods and services and the staff were previously unemployed.

Temporary construction workers would spend a portion of their incomes on local goods and services, but they would transfer most of their incomes back to their permanent residences in communities outside of the County.

During the Project’s O&M activities, there would be no noticeable impact on the county’s employed workers or their incomes. Most of the workers hired for the Project’s O&M activities would be long-term specialty workers with established O&M careers in the electric power transmission industry. Their new salaries for the Project’s O&M activities would likely be similar to their previous salaries.

Housing Across Aurora, Byers, Deer Trail, and Strasburg, there are approximately 7,606 vacant housing units and several hotels/ motels with approximately 112 rooms to accommodate the Project’s temporary construction workers. These workers’ short-term housing lease payments and guest room fees and taxes would provide a temporary increase in local and regional housing revenue streams. After construction activities are completed, it is anticipated that housing conditions would return to pre-construction conditions.

Net Effect of the Project on the Local Economy The Project would be expected to have a net positive effect on Arapahoe County’s economy. More specifically, as temporary construction workers relocate to the county, their expenditures on goods, services, and housing would increase local revenue streams and associated state and local tax revenues. Should a few workers relocate to the county for permanent O&M employment, they would likely have a small but positive impact on the local economy through purchasing goods, services, and long-term housing. Family members joining these workers might also contribute to the local economy’s growth in obtaining employment and increasing total household incomes in the county.

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Opportunities for Economic Diversification The Project would not be expected to diversify the local economy’s existing mix of employment sectors. The addition of a new transmission line in the county would not represent a different kind of facility or require skills that are different from those used to construct existing transmission lines in the county. PSCo anticipates employing 12 - 30 workers during the Project’s construction period and 6-10 workers during the Project’s O&M period.

5.11 Hazards and Emergency Procedures Hazards, such as fire and the accidental spill of hazardous materials, could occur with the construction, O&M of the Project. These hazards and procedures for reducing them are described in more detail below.

5.11.1 Fire Fire ignition in the Project Area could occur through natural causes (i.e., lightning) and human activities. The Project could increase fire ignition through construction and O&M activities (e.g., vehicle ignition). The implementation of the following BMPs will reduce potential hazards from fire:

• PSCo and its contractors, as appropriate, will initiate discussions with local fire districts and regional fire prevention staff prior to construction to discuss emergency procedures and to provide transmission line safety training, including safety procedures for conducting fire suppression activities near a power line. • All construction, O&M vehicles will be equipped with appropriate fire suppression tools and equipment. Fire suppression equipment will include, but not limited to, shovels, buckets, and fire extinguishers. • Smoking and equipment parking will be restricted to designated areas and prohibited in the vicinity of flammable materials. • PSCo and /or its contractors will fuel all highway-authorized vehicles off-site to minimize the risk of fire. Fueling of construction equipment that is transported to the site via truck and is not highway authorized will be done in accordance with regulated construction practices and federal, state, and local laws. • PSCo and/or its contractors will notify the federal, state, and local agencies of any fires and comply with all rules and regulations administered by the federal, state, and local land management agencies concerning the use, prevention, and suppression of fires including any fire prevention orders that may be in effect at the time of the construction, operation, or maintenance activity.

5.11.2 Accidental Spills During construction, use of trucks, heavy equipment, or stored supplies could result in accidental discharge of fuel, lubricants, and automotive fluids. Although the potential exists, any spills would be accidental, occasional, and of limited extent and would be considered minor to negligible and temporary in duration. A Spill Prevention, Containment, and Countermeasure Plan will be prepared for the proposed Project and will contain information regarding training, equipment inspections maintenance and repair, spill prevention kits, and refueling operations for construction vehicles, with an emphasis on preventing spills. Hazardous materials will not be drained onto the ground or into streams or drainage areas. All construction waste including trash and litter, garbage, other solid waste, petroleum products and other

PAGE 109 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

potentially hazardous materials will be removed to a disposal facility authorized to accept such materials weekly.

5.12 Cost-Benefit Analysis The Project will present benefits to Arapahoe County, the State of Colorado, and PSCo’s ratepayers. There are also limited costs associated with the Project. Costs and benefits are summarized below.

Potential Project benefits include:

• Increased tax base for Arapahoe County; • Landowner easement payments provide additional income for residents; • Local spending for Project construction materials and other goods and services; • Economic generation for the State of Colorado for Project construction materials and other goods and services; • Long-term cost savings for PSCo ratepayers; • County road maintenance and improvements; • Facilitating renewable, sustainable energy for the State of Colorado; and • Support to local community organizations and events. o Sponsorship of County Fair events; and o Support community organizations (i.e., fire, ambulance, schools, libraries, community centers, churches, 4-H, FFA, etc.).

Potential Projects impacts include:

• Visual impacts due to heights of transmission line structures (see Section 5.3 Visual Resources); and • Minimal community and local governmental service demands, including minor impacts to emergency, fire, and safety services

PAGE 110 Public Service Company of Colorado Rush Creek 345 kV Transmission Line Project Arapahoe County 1041 Application-REV03

6. ENGINEERING STUDIES

6.1 Floodplain Delineation Study A floodplain delineation study will be prepared as a condition of approval. The floodplain study will be submitted to Arapahoe County under a separate cover to address issues associated with the proposed transmission line.

6.2 Grading, Erosion, and Sediment Control A grading, erosion, and sediment control study (“Study”) was prepared for the original construction of the Missile Site Substation in 2012. The 2012 Study was prepared to account for the buildout of an additional 345kV transmission and therefore covers the proposed Project. A new Grading, Erosion, and Sediment Control Study for the transmission line will be prepared, submitted, and approved prior to construction.

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7. REFERENCES

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_____. 2010a. Arapahoe County 2035 Transportation Plan. Adopted December 7, 2010. Available at: https://www.arapahoegov.com/index.aspx?NID=948. Accessed on July 5, 2016.

_____. 2010b. Arapahoe County Open Space Master Plan. Available at: http://co- arapahoecounty.civicplus.com/index.aspx?NID=462. Accessed on June 16, 2016.

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Bailey, R.G. 1995. Description of the Ecoregions of the United States, second edition. Miscellaneous Publication 1391 (revised). Washington, DC: U.S. Department of Agriculture, Forest Service. Available at: http://www.fs.fed.us/land/ecosysmgmt/ecoreg1_home.html.

Chapman, S.S., Griffith, G.E., Omernik, J.M., Price, A.B., Freeouf, J., and Schrupp, D.L., 2006, Ecoregions of Colorado (color poster with map, descriptive text, summary tables, and photographs): Reston, Virginia, U.S. Geological Survey (map scale 1:1,200,000). Available online at: http://ulpeis.anl.gov/documents/dpeis/references/pdfs/Chapman_et_al_2006.pdf. Accessed on June 21, 2016.

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Colorado Department of Labor. 2015. Statistics for construction wages per the state’s Labor Market Information Gateway. Available online at https://www.colmigateway.com/vosnet/Default.aspx. Accessed on June 30, 2016.

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Colorado Geological Survey. 2016. Colorado Points of Geological Interest. Available online at: http://coloradogeologicalsurvey.org/colorado-geology/colorado-points-of-geological-interest/. Accessed on June 24, 2016.

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Colorado Parks and Wildlife (CPW). 2003. Conservation Plan for Grassland Species in Colorado. 205 pp. Available online at: http://cpw.state.co.us/Documents/WildlifeSpecies/Grasslands/plan.pdf Accessed on June 29, 2016.

_____. 2004. Rare Whooping Crane Spotted in Colorado, CPW News Release. Available online at: http://cpw.state.co.us/aboutus/Pages/News-Release-Archive-Details.aspx?NewsID=1598 Accessed on June 24, 2016.

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_____. 2013. Swift Fox Sighting Investigation Report. Available online at: http://cpw.state.co.us/Documents/WildlifeSpecies/Grasslands/SwiftFoxSightingReportMay2013.p df. Accessed on June 24, 2016.

_____. 2016a. Least Tern Species Distribution and Habitat factsheet. Available online at: https://cpw.state.co.us/Documents/LandWater/WetlandsProgram/PrioritySpecies/Factsheet-and- Habitat-Scorecard_LeastTern.pdf Accessed on June 24, 2016.

_____. 2016b. Piping Plover Species Distribution and Habitat factsheet. Available online at: https://cpw.state.co.us/Documents/LandWater/WetlandsProgram/PrioritySpecies/Factsheet-and- Habitat-Scorecard_PipingPlover.pdf Accessed on June 24, 2016.

_____. 2016c. Long-billed Curlew Species Distribution and Habitat factsheet. Available online at: https://cpw.state.co.us/Documents/LandWater/WetlandsProgram/PrioritySpecies/Factsheet-and- Habitat-Scorecard_LeopardFrogs.pdf Accessed on June 24, 2016.

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Colorado State University. 2016. Managing Pocket Gophers, Natural Resources Series, Fact Sheet No. 6.515. Available online at: http://extension.colostate.edu/docs/pubs/natres/06515.pdf Accessed on June 24, 2016.

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Dahl, T.E. 1990. Wetland losses in the United States 1780’s to 1980’s. Washington, DC: U.S. Fish and Wildlife Service. 21 pp.

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Environmental Protection Agency. 2012. 2012 Waterbody Quality Assessment Report. Available at: https://iaspub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=COSPLS02B_1600&p _cycle=2012&p_state=CO&p_report_type=T#causes. Accessed on June 22, 2016.

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Natural Resources Conservation Service (NRCS). 2016. Soil Survey Geographic (SSURGO) database for Arapahoe, Elbert, and Lincoln counties. Available online at: http://SoilDataMart.nrcs.usda.gov/. Accessed June 23, 2016.

Playa Lakes Joint Venture (PLJV). 2016. Maps of Probable Playas. Available online at: http://pljv.org/for- habitat-partners/maps-and-data/maps-of-probable-playas/. Accessed on June 23, 2016.

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Rocky Mountain Bird Observatory (RMBO). 2000a. Burrowing Owl (Athene cunicularia). Physiographic Region 87: Colorado Plateau. Accessed online at: http://www.rmbo.org/pif/bcp/phy87/semi- des/buow.htm Accessed on June 24, 2016.

Rocky Mountain Bird Observatory (RMBO). 2000b. Plains Sharp-tailed Grouse (Tympanuchus phasianellus jamesi) Physiographic Region 36: Central Shortgrass Prairie. Accessed online at: http://www.rmbo.org/pif/bcp/phy36/grasland/stgr.htm. Accessed on June 24, 2016.

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Rocky Mountain Bird Observatory (RMBO). 2000c. Snowy Plover (Charadrius alexandrinus) Physiographic Region 36: Central Shortgrass Prairie. Available online at: http://www.rmbo.org/pif/bcp/phy36/shore/snpl.htm. Accessed on June 24, 2016.

Stone, K.R. 2009. Grus canadensis. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available online at: http://www.fs.fed.us/database/feis/animals/bird/grca/all.html. Accessed on July 5, 2016].

SWCA. 2016. Final Report for Raptor Nest Survey Rush Creek Wind-generated electricity Project. Report prepared for Invenergy Wind Development LLC. June 2016.

U.S. Census Bureau (USCB). 2014. United States Census Bureau data for population, employment and income, and housing in Arapahoe County, Colorado. Available: http://factfinder.census.gov/. Accessed on June 18, 2016.

_____. 2015. United States Census Bureau data for population data for Arapahoe County, Colorado and the State of Colorado. Available: http://www.census.gov/quickfacts/. Accessed on June 18, 2016.

United States Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS). 2006. Land Resource Regions and Major Land Resource Areas of the United States, the Caribbean, and the Pacific Basin. U.S. Department of Agriculture Handbook 296.

USDA. 2016. “Plant Database,” plants.usda.gov, United States Department of Agriculture, Natural Resources Conservation Service. Accessed on June 22, 2016.

U.S. Fish and Wildlife Service (USFWS). 1993. Pallid sturgeon recovery plan (9.65 MB). USFWS, Denver, Colorado. 55 pp. Available online at: https://www.fws.gov/southdakotafieldoffice/STURGEON.HTM. Accessed on June 24, 2016

_____. 2016. “IPaC- Information, Planning and Conservation System”, Available online at: http://ecos.fws.gov/ipac/ Accessed on June 22, 2016.

_____. 2016a. USFWS Critical Habitat Mapper, Environmental Conservation Online System Available online at: http://ecos.fws.gov/ecp/report/table/critical-habitat.html Accessed on June 22, 2016.

_____. 2016b. Central Flyway Mid-Winter Survey Results. Available online at: https://www.fws.gov/migratorybirds/pdf/management/Flyways/CFMWS2016.pdf Accessed on June 29, 2016.

U.S. Fish and Wildlife Service (USFWS) and Colorado Parks and Wildlife (CPW). 2007. Ecology of the Desert Massasauga Rattlesnake in Colorado: Habitat and Resources Utilization. Available online at: https://cpw.state.co.us/Documents/WildlifeSpecies/Grasslands/2007EcologyofDesertMassasauga RattlesnakeinCO.pdf Accessed on June 24, 2016.

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Van Graham. 2014. Colorado Greater Sandhill Cranes. Available online at: http://coloradocranes.net/crane-facts/colorado-greater-sandhill-cranes/. Accessed on June 24, 2016.

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